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SpeakUp&BeHeard

 

At Chiesi, we take very seriously our commitment in relation to transparency and compliance. To help us to discover and address any possible breach of Chiesi Code of Conduct, violation of laws or regulations or misconduct that could put Chiesi business or reputation at risk or cause damage to third parties, we welcome and encourage the reporting of such matters.

SpeakUp&BeHeard is the internal reporting channel implemented by Chiesi in such regard.

This system:

  • allows anyone to make a report through a web-based platform (independent from Chiesi IT system and common across the Group, hereinafter "Platform"), or through a voicemail accessible through a dedicated toll-free number;

  • is structured to warrant the highest standards of protection of confidentiality towards the report, the reporter, the persons involved in the reported conduct, in line with the requirements set forth under Legislative Decree No. 24/2023 (hereinafter “Decree 24/23” or “Decree”) on the protection of persons who report breaches of Union and national laws (please, check Chiesi Privacy Notice).

When reporting through "SpeakUp&BeHeard" ("SU&BH") you can choose to disclose your personal data or remain anonymous.

Even if you choose to remain anonymous, we suggest that you identify yourself, to be contacted by the Manager if more information is needed to assess the report.

Through SU&BH you can report any breach (whether relevant or not for the purposes of Decree 24/23), following the procedures and information set out in the Operating Instructions.

We guarantee that reporters will always be protected

We are committed to protecting reporters against any form of discrimination and/or retaliation in relation to reports communicated in good faith:

No retaliatory action will be taken against reporters who, at the time of the report, had grounded reasons to believe that the information about the violation reported was true. In case of reports relevant for the purposes Decree 24/23, actions mentioned under Article 17 of the Decree will be considered retaliatory where adopted against reporters and the further persons/entities specified in the same Decree (e.g. facilitators, persons in the same work environment and linked to the reporter by a stable affective bond, etc.).

Report management

Reports affecting Chiesi Farmaceutici S.p.A. or in any case sent – through the Platform – to "Chiesi Corporate" (based on the information reported within the Operative Instructions) will be managed by the Group Compliance Function of Chiesi Farmaceutici S.p.A. ("Manager").

External reporting

When reporting conducts/events relevant for the purposes of the Decree 24/23, you can only make reports to the Italian Anticorruption Authority (ANAC) where one of the following conditions is met:

  • you have already made a report via SU&BH and it has not been followed up;

  • you have reasonable grounds to believe that, if you made a report via SU&BH, it would not be effectively followed up or that the same report may result in the risk of retaliation;

  • you have reasonable grounds to believe that the violation detected may pose an imminent or clear danger to the public interest.

The modalities for external reporting are provided by ANAC at https://www.anticorruzione.it/-/whistleblowing

Any report submitted through "SpeakUp&BeHeard" will be given due consideration and will undergo a proper assessment process.

 
SpeakUp&BeHeard

If you decide to communicate a report through SpeakUp&BeHeard voicemail or make an appointment with the Manager, you need to dial the toll-free number 800977912 and follow the instructions provided.

The number from which you make the call will always be visible to the Manager. Furthermore, if the call is made through Chiesi’s Teams Channel, or via the mobile phone provided by Chiesi, also your name will be visible to the Manager. Even if you decide to activate the "hide ID" feature, the Manager may still have access to such information.

In case the report is made through the voicemail, you will not have the opportunity to access the Platform to check your report status, since no univocal identification code will be released.

In the event that you do not provide a telephone number or do not identify yourself, your report will be treated as an anonymous report and no dialogue with the Manager can be guaranteed.