WHISTLEBLOWING

The OTB Group is committed to conducting business in an ethical and responsible way. The Group Code of Ethics is a fundamental guide to ensure high standards in terms of integrity, behavior, and responsibility. The Code describes our values - courage, respect, excellence, evolution - and the principles that the Group complies with in the conduct of its affairs, in the exercise of its activities and in managing relationships with all our stakeholders.

This culture of integrity is pivotal to conducting the business in compliance with the OTB Group Code of Ethics, law and regulations, Model 231/01, where applicable, and the Group policies and procedures.

The Group has established a dedicated whistleblowing channel for the submission of reports related to potential/suspected violations under the Directive (EU) 2019/1937 of the European Parliament and of the Council, of October 23, 2019, on the protection of persons who report breaches of Union law (the so-called "Whistleblowing Directive") and related implementing laws in Union countries, as well as the Group Code of Ethics and/or, more broadly, internal procedures and applicable law.

WHAT YOU CAN REPORT

The Group strongly encourages all its stakeholders to report any illegal conduct, behaviors, acts or omissions that harm the company, violations of the Organizational, Management and Control Model, where applicable, and thus any conduct or situation contrary to the Group code of ethics, illegal activities that fall within the scope of application of European Union or national acts.

HOW TO REPORT

Reports can be submitted using the digital reporting platform at the following link.  

The channel is suitable to ensure the confidentiality of the sources and information obtained and to guarantee the anonymity of the report.

WHAT NOT TO REPORT THROUGH THIS CHANNEL

Please do not use this platform for report related to complaints, disputes or requests related to a personal interest of the Whistleblower; information clearly lacking foundation; information that is already available and in the public domain; information obtained based on speculations or rumors; commercial requests and complaints.

For further information on Whistleblowing channel and the process to submit a report please refer to Whistleblowing Management policy.