Whistleblowing

Arper SPA encourages employees and third parties working with the Group to report any problems related to violations of the Code of Conduct or potentially critical situations connected with violations of the law (whistleblowing).

To facilitate whistleblowing, Arper SPA has equipped itself with an electronic tool. The electronic tool is external to Arper systems and is managed by MYGO s.r.l. with offices in Via del Corso 92 Rome, VAT no. 14356531005.

The whistleblower can access it via an internet link. On first access, the whistleblower must read a document explaining how the whistleblowing software works. Once the report has been entered, Arper Spa’s Supervisory Body will take care of the matter and use the electronic tool to communicate with the whistleblower.
In no case will Arper be able to access the system.

Employees have access to the tool through an Internet link. Once the report has been entered, Arper Spa’s Supervisory Body will take care of the matter and use the electronic tool to communicate with the whistleblower.
In no case will Arper be able to access the system.

The report may be sent using the following communication channels:

  • via web form following registration with the system

to register access the following link https://www.mygovernance.it/token-arper/
to make a report access the following link https://areariservata.mygovernance.it/

  • by mail sent to:

Organismo di Vigilanza (Supervisory Body) c/o Arper Spa
Via Lombardia 16,
31050 Monastier di Treviso (TV), Italy

 

For further information, you can read our FAQ.
 

General information on Arper Spa’s Whisteblowing Procedure


What is the Mywhistleblowing tool?

Mywhistleblowing is a tool that the Arper Group has equipped itself with and that gives users the opportunity to confidentially report any concerns about actions or practices that may infringe internal or external company rules, including the provisions of the Group’s Code of Conduct.


Why do we need a tool such as Mywhistleblowing?

The Arper Group promotes a positive and happy work environment through the creation of freely accessible communication channels. An effective whistleblowing system broadens our commitment to promoting a culture of ethics and integrity.
Recent studies show that web forms managed by external providers are frequently used by employees and third parties. Companies find that these reporting systems are effective for detecting violations of the law or of rules of conduct.


Can I choose to use the Internet or conventional mail to make a report? What happens if I don’t have access to the Internet?

Confidential reports can be made either via the Internet or using conventional mail.
If you don’t have access to the Internet or you’re not good at using a computer, you can send a letter by post.


Why do I need to enter a Username, email and password to access the service?

You need to enter a username, password and email to make sure there is communication between the whistleblower and the Supervisory Body. This is not possible when normal token systems are used.
Furthermore, if the whistleblower were to forget the token (which is more than likely), he/she would no longer be able to access the report he/she has made. Lastly, the whistleblower must remember to access the system from time to time to check if there are any comments or simply to receive the outcome of the report.
With our system, instead, alerts are anonymous and are sent by email. They inform the user that he/she needs to connect to the system because an event has occurred requiring his/her attention.
This means greater security, greater confidentiality, greater efficiency and greater effectiveness.
As further guarantee for the whistleblower, both login and email can be entered anonymously so that they do not lead to the whistleblower.


Can I make an anonymous report?

When permitted by local regulations, you can choose to make an anonymous report or you can identify yourself. However, even if anonymous reports are accepted, we believe that investigations can be handled more effectively if the whistleblower’s identity is known.



Whistleblowing


Which events can I report?

Arper’s Mywhistleblowing procedure can be used by Group employees and third parties to report practices or behaviour which, in good faith, are considered inappropriate or do not comply with the law, the Group’s Code of Conduct or other company rules, provided that the practice or behaviour reported concerns one of the following issues: financial management, auditing and accounting administration, practices related to the use of means of payment, and the fight against corruption. To report practices or behaviour relating to issues other than those just mentioned, you may use one of the other local or Group reporting channels. Details are available on the Arper Group website.
Reports must be appropriately detailed.


Which events CANNOT be reported using this channel?

Arper’s Whistleblowing procedure (which includes the web form) cannot be used to report events leading to an imminent threat to life or property. Reports submitted through this service may not receive immediate response. If you need assistance in an emergency, please do not hesitate to contact the competent authorities and bodies.
Furthermore, reports from customers regarding products or services offered by Group companies cannot be made through this channel: reports of this kind must be handled according to specific procedures and must therefore be sent using specific channels, which are detailed on the company’s website or in the product/service contract documents.


I’m not sure whether what I saw or heard infringes a regulation or company rule or can be considered immoral behaviour, but it seems to be wrong. What can I do?

You can contact the company’s Supervisory Body.


If, as a Group employee, I become aware of a violation, can I report it directly to my manager and let him/her deal with it?

You can certainly decide to report the violation to your manager. However, in some circumstances, you may not feel comfortable doing so or you may find it more appropriate to use alternative reporting channels. It is exactly to deal with these kinds of situations that other reporting channels have been provided to you (such as the Supervisory Body’s mail and email addresses - published on the company’s website) and that the Whistleblowing procedure has been set up.


Why should I make a report? What are the benefits for me?

We all have the right to work in a positive environment. This right is closely related to our responsibility to behave ethically and correctly in our work environment and in our relations with third parties. This is why we must ensure that the competent company departments receive information about whoever is not behaving correctly.
Inappropriate conduct could jeopardise the Group and threaten the good performance of the business and our reputation.


Does management really want me to make reports?

Management wants you and needs you to make them. You may be aware of an activity that may be of concern to the company. Your report could minimise potential negative impacts on the company, its employees and third parties.


As an employee, could making a report lead to negative effects on me?

The Group strictly prohibits any form of retaliation against people reporting in good faith, regardless of whoever is involved.


What happens if, after I’ve made a report, I remember further important details or if the person who is handling the report needs to ask me questions about the event I’ve reported?

When you make a report using the Mywhistelblowing web form, you are given a code and asked to choose a password. Using these credentials will allow you to call the Mywhistleblowing process, access the web form and access your report to add further details or answer questions that may be put to you by the person handling the report and to provide further information that may be helpful in resolving outstanding issues. We strongly recommend that you consult the site according to the timing notified to you to answer any questions. Even when you choose to make an anonymous report, you can enter into an “anonymous dialogue” with the person in charge of investigating the case.


What happens if the report is unfounded upon the outcome of the investigation?

If the report is found to be unfounded or unjustified, Arper Spa’s Supervisory Board will close the case. All whistleblowing documentation will be kept only for the time necessary.


What happens if the report is well-founded upon the outcome of the investigation?

If the report is well-founded, Arper Spa’s Supervisory Body will identify the corrective measures to be implemented and will consider whether to apply disciplinary sanctions, taking into account current legislation and internal regulations. Any decision on the matter will be referred to the CEO or other competent administrative body.
All whistleblowing documentation will be kept only for the time necessary.



Security


I think my company computer authenticates with the server and this allows keeping track of every site I visit. Can I be identified as a whistleblower for this reason?

The Mywhistelblowing system does not generate or keep any authentication data related to the IP address. This means that it is not able to provide information that links your computer to its use.
In any case, if you don’t feel comfortable about making a report from your company computer, you can still connect to the Mywhistleblowing website using other computers (e.g., those available in Internet Cafés or at a friend’s home, etc.).


I’m afraid that the information I provide to Mywhistleblowing may ultimately reveal my identity. How can I be sure this won’t happen?

The Mywhistleblowing procedure has been designed to protect anonymity. If you wish to remain anonymous, please take care not to give details in your report which could reveal your identity (e.g. avoid sentences such as: “from my desk next to Gianni Rossi’s...” or “In my 45 years of life...” or using a login and email that can lead to your identity).


How can I identify myself?

The questionnaire available on the website contains a whistleblower identification section that you can use for this purpose.



Confidentiality and data protection


Are the reports received and the data they contain handled confidentially?

Yes, regardless of whatever whistleblowing channel you decide to use, any reports and subsequent communications, as well as all the data and information concerning the persons involved, will be considered strictly confidential and will be handled with utmost confidentiality, in compliance with the requirements of the company’s data protection provisions and of applicable legislation.


What information do I need to give when making a report?

Only information that is necessary to start investigating the reported event should be given. When making a report, avoid giving information about the private life of individuals, i.e. sensitive data, such as details on their health or sex life, if information of this kind is not strictly necessary or directly related to your report. You should also avoid giving information about people who are not involved in or related to the report.


What happens to my reports? Who can see them?

Your reports are entered directly into the protected servers of the external provider MYGO s.r.l. (Software provider) Via del Corso 92, Roma VAT No. 14356531005 in order to prevent possible security violations. They may be examined and, as a consequence, the information in them may be used only by individuals who need them for work purposes and in any case in accordance with Arper Group’s violation management process or if required by law. The parties that have access to whistleblowing information include Arper Spa’s Supervisory Body and the technical staff of the supplier MYGO s.r.l.. Reports will in any case be handled with utmost confidentiality and in compliance with ARPER Group’s whistleblowing management process.

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