Reports of alleged irregularities
What is "Whistleblowing"?
The term whistleblowing refers to the reporting by an individual, called a "whistleblower", of an unlawful conduct or irregularity committed in the business context with which he or she has a qualified relationship or carries out activities of any kind (shareholder, director, employee, self-employed worker, trainee, volunteer), of which he or she has witnessed or of which he or she has become aware, deemed detrimental to the public interest or the integrity of the company.
Across the AXA Group, regardless of the meaning of the term whistleblowing in local law, "reporting of suspected wrongdoing" means the action by which a person (employee or non-employee) informs about, discloses or reports any type of conduct, information, operation or activity that is alleged to be inappropriate, incorrect, unethical or unlawful (or even just potentially unlawful or appears to be illicit).
Why is it so important to make a report?
The companies of AXA Partners - Italy, directed and coordinated by AXA Partners Holding S.A., confirm their commitment to act with the highest standards of honesty and integrity.
This commitment is essential both for the strictest compliance with laws and regulations, and for consistently winning and maintaining the trust of our customers, shareholders, employees and business partners.
In this context, AXA Partners - Italy is committed to protecting the people who report violations, as a valuable and essential contribution to the correct pursuit of the described objectives.
In particular, AXA Partners - Italy encourages you to promptly report any action, omission or practice deemed inappropriate or not compliant with the laws, regulations, the Organization, Management and Control Model, the AXA Compliance & Ethics Code and AXA Partners Anti-Corruption Code of Conduct and any internal policy or procedure.
What can be reported through Whistleblowing?
The reports, according to European and national legislation, may concern:
- actual or potential violations, of which there is knowledge or even only a well-founded suspicion,
- conduct that is presumed to be inappropriate, incorrect, unethical or unlawful (or even only potentially unlawful or apparently unlawful),
- any crime, including in the form of an attempt, or administrative offences,
occurred or possibly occurred in AXA Partners-Italy, as well as the attempted or perpetrated concealment of such violations, conduct or crimes.
By way of example and not exhaustively, alleged irregularities may relate to:
- Bribery, Corruption & Conflict of Interest
- Money laundering, financing terrorism or breaching sanctions
- Internal fraud
- Financial Misstatements
- Sexual harassment
- Other harassment
- Discrimination
- Inappropriate behaviour
- Theft of money, belongings, or assets
- Leakage of data or intellectual property
- Breach of other laws & regulations
- Hazards to Health, Life and Safety.
In addition to the examples above, conduct related to the additional regulatory areas provided by Legislative Decree 24/2023 is also relevant, in consideration of the activity carried out.
How can I make a report?
The AXA Group encourages you to promptly report any practice or action that you consider inappropriate or non-compliant.
To this end, AXA Partners - Italy provides various communication channels (with the possibility of meeting in person), through which it is possible to make the report, anonymously or not:
- reporting tool accessible at https://axapartnersit.integrityline.com/?lang=en; it is suggested to prefer this mode of communication as the channel is designed to ensure maximum confidentiality and security of reports and reporting subjects, in compliance with current regulations;
- local e-mail address whistleblowing@partners.axa, which is accessed only by the Head of Internal Audit AXA Partners and expressly authorised employees of the AXA Partners Internal Audit Function;
- ordinary mail addressed to the Head of Internal Audit AXA Partners; in this case, in order to take advantage of the guarantee of confidentiality, it is necessary that the report is placed in a sealed envelope that bears the words "confidential/personal" on the outside; in order to strengthen the guarantee of confidentiality, the whistleblower should insert two other sealed envelopes inside this envelope, one containing the description of the report, and the other one with identification data (if anonymity has not been chosen);
- Group e-mail address speak-up@axa.com, accessed by the Head of the Investigation structure in the AXA S.A. Group (Paris) dedicated to the management of cases of alleged irregularities.
In addition to the internal reporting channels mentioned above, external reporting can be made directly to the National Anti-Corruption Authority (ANAC) and through public disclosure. These procedures are provided only and exclusively on a residual basis, in the cases defined by the legislator, reported within the ANAC Guidelines and available on the website: https://www.anticorruzione.it/-/whistleblowing.
What is the timing of the handling of the report?
- Acknowledgment of receipt of the report to the whistleblower within seven days from the date of receipt;
- Following examination of the report, feedback to the whistleblower on the outcome of the investigation or, if not concluded, on the progress of the activities, within three months from the date of the acknowledgement of receipt or, in the absence of such notice, within three months from the date of expiry of the seven-day deadline for such notice.
How is the Whistleblower protected?
The legislation requires that the confidentiality of all those involved in the report is upheld.
In addition to the whistleblower, the protection extends also to the related facilitators, colleagues or relatives.
The whistleblower, insofar as good faith is recognisable, is protected by law and internal procedures, which impose the utmost protection and confidentiality, even if the reported facts subsequently prove to be unfounded or inaccurate.
This means a guarantee of:
- confidentiality: the identity of the reporting person and any other information from which such identity may be inferred may not be revealed, without the express consent of the same and except in the cases expressly indicated and regulated by the legislator, to persons other than those competent to receive or follow up on allegations, expressly authorised to process such data;
- protection from "retaliation" (e.g. disciplinary sanctions, discriminatory measures, or acts with potential related harmful consequences).
The same confidentiality and protection are also foreseen for the persons involved and those mentioned in the report.
However, in the event of reports made in bad faith, AXA Partners-Italy reserves the right to act in defence of their interests and to protect the injured parties and may apply sanctions or report to the competent authorities those who make reports in bad faith or for the sole purpose of damaging the companies, the reported person or other parties affected by the report. In addition, the same measures will be applied to the individuals who violated the protection actions that should be applied to the whistleblower.
Privacy Notice
As part of the process of managing reports of alleged irregularities, personal data is processed in compliance with current legislation on the subject, according to the privacy notice available by clicking here.
Main reference legislation