Our system for reporting unlawful conduct — “Whistleblowing”

Lighthouse STP S.r.l. is committed to promoting a corporate culture based on ethical conduct and sound corporate governance, thereby fostering an environment in which people are encouraged to report unacceptable conduct within our organisation.

For this reason, Lighthouse STP has established specific channels, processes and procedures to guarantee confidentiality and protection from retaliation for those who report unlawful conduct.

Reports may concern violations and/or irregularities relating to the matters governed by the attached Whistleblowing Policy and by external regulations.

More specifically, by way of example and without limitation:

  • Corruption;
  • Money laundering;
  • Breach of the regulations on Financial Sanctions;
  • Breach of antitrust laws;
  • Insider trading and/or market manipulation;
  • Harassment;
  • Bullying;
  • Fraud;
  • Improper use of confidential client and Company data;
  • Breach of the Code of Ethics and/or the Code of Conduct;
  • Breaches of the Organisation and Management Model pursuant to Legislative Decree 231/01.

Reports must be submitted through one of the following channels:

By email
By sending an email to the following address: odvlighthousesta@gmail.com

In writing
By sending a written report marked “CONFIDENTIAL”/“PERSONAL” by post or by hand, addressed to: OdV Lighthouse STA S.r.l., c/o the registered office of the same company, indicating an address or a mobile contact number in order to manage the report.

Orally
By calling the number 0586.880649 and requesting a telephone appointment with the Supervisory Body (Organismo di Vigilanza) of Lighthouse STA S.r.l., Avv. Paolo Mascitelli.
The channels indicated above may not be used to lodge a complaint relating to the commercial relationship, but only to report unlawful conduct.
Please note that, in Italy, in implementation of Legislative Decree 24/23, the National Anti-Corruption Authority (ANAC) has been identified as the authority responsible for receiving and managing external reports, including in anonymous form.

The Reporting Person may therefore make an external report to ANAC if, at the time it is submitted, one of the following conditions applies:

  • there is no mandatory internal reporting channel within their working environment, or such channel — even if mandatory — is not active or, even if activated, does not comply with the requirements of the law;
  • they have already made an internal report and it was not followed up;
  • they have reasonable grounds to believe that, if they made an internal report, it would not be effectively followed up, or that the report itself could give rise to a risk of retaliation;
  • they have reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

In addition, the Reporting Person may also contact ANAC to report any acts of retaliation resulting from a report.

External reports to ANAC may be made in accordance with the procedures set out on the authority’s official website.

Download the Whistleblowing Procedure