Reporting of wrongdoing and irregularities
Definition
The whistleblowers are those who are part of the Juventus organisation, (both employees, collaborators and those who hold representative, administrative or managerial functions or who exercise, even de facto, management and control), or customers, suppliers, commercial partners, financiers, consultants, former employees and, in general, all those who have relations with Juventus, if they become aware of a situation that could be reported.
The report (so-called whistleblowing) is the communication made pursuant to and using the methods envisaged by the related procedure , concerning a situation that the whistleblower deems to be reportable because he/she believes it may constitute a violation.
Whistleblowing is the mechanism that makes it possible to report offences and misconduct potentially damaging to the integrity of the organisation, based on well-founded reasons.
The main purpose of whistleblowing is to promote a culture oriented towards fairness and legality and aims to define the rules to be followed in the process of report management.
In particular, whistleblowing discipline sets forth a set of rules and procedures aimed at incentivising and protecting against retaliation and discrimination an employee who reports offences or irregularities of which they have become aware while performing their duties
The Violations are those behaviors, acts or omissions that are detrimental to the interest or integrity of the Company of which the Whistleblower has become aware in the work environment, in the following areas:
- violations of national and European Union regulatory provisions that harm the public interest or the integrity of the public administration or private entity, as referred to in the applicable legislation,
- violations of the Code of Ethics,
- violations of the 231 Model,
- violations of the FIGC Prevention Model,
- violations of the Safeguarding Policy,
- serious and/or repeated violations of internal procedures and regulations of Juventus, even if not explicitly referred to in the aforementioned Models or the Code of Ethics,
- violations of laws and regulations (football and non-football-related) applicable to the reference sector,
- administrative, accounting, civil or criminal offences not covered by the previous points.
1. NORMATIVE SOURCE AND NATURE OF THE INSTITUTION
You can find the regulatory references, always updated, on this page
2. SUBJECT OF THE REPORT
It doesn't exist an obligatory list of types of wrongdoing that can be subject of whistleblowing, but you can refer to the violations as defined above and to the platform wizard.
Juventus supports and encourages reports from anyone who in good faith has certain information or a reasonable suspicion, based on well-founded reasons, that a violation as defined above has occurred or may occur. On the contrary, neither mere rumours, nor complaints/claims of a personal nature, nor any assessments, criticisms or complaints about the management and administration of the company, both in business and football-related terms, must be subject to reporting, unless factual elements are identified that may constitute a violation as defined above.
3. CONTENT OF THE REPORTS
The whistleblower must supply all the useful elements to consent to the Whistleblowing Committee and his collaborators, to proceed with the proper and appropriate verifications that certify the validity of the facts that are subject of the reports.
4. REPORT MODALITY AND RECIPIENTS
Juventus lets everybody raise concerns through a software application accessible through the intranet. The software application guarantees absolute confidentiality and encryption of whistleblower's identity and content of the report, exclusively known by the recipient.
5. ACTIVITY OF VERIFICATION OF THE VALIDITY OF THE REPORT
The management and the verification of the validity of the circumstances described in the report are entrusted to the Whistleblowing Committee who provide, in accordance with the principles of impartiality and confidentiality.
For this purpose, the Whistleblowing Committee rely on the support and the collaboration of the competent corporate structures and, if necessary, of supervisory bodies external to the Company, as better specified in the procedure
6. PROTECTION OF THE WHISTLEBLOWER
Juventus undertakes to keep confidential the identity of the Whistleblower and of the other subjects who, even though they did not made the report directly, are nonetheless deemed to deserve protection, subject to legal obligations and the protection of the rights of Juventus or of persons accused incorrectly and/or in bad faith.
Juventus undertakes to protect the Whistleblower acting in good faith against any form of retaliation, discrimination or penalisation for reasons linked, directly or indirectly, to the Report.
The Company prohibits direct or indirect acts of this form against the Whistleblower and provides for disciplinary sanctions against those who breaches this prohibition or the obligations to protect the confidentiality of the Whistleblower's identity.
7. RESPONSIBILITY OF THE WHISTLEBLOWER AND PROTECTION OF THE REPORTED PERSON
The Whistleblower shall be liable for the Report made. The Company prohibits forms of whistleblowing “abuse," involving reports that are manifestly opportunistic and/or made for the sole purpose of damaging the Reported Person, and any other circumstance of improper or instrumental use of the reporting mechanism are prohibited. Disciplinary sanctions are envisaged against anyone who breaches this prohibition, by making reports with willful misconduct or gross negligence that are found to be groundless, without prejudice to any ascertainment of civil liability (pursuant to Article 2043) or criminal liability (in cases involving a slanderous or defamatory report pursuant to the Italian Criminal Code).The same protection extends to any Reported Persons that are external to the Juventus organisation (e.g. other collaborators, suppliers, licensees, partners and "other parties", according to the definitions of the Code of Ethics).