Home / Discover Monge / Code of Business Conduct and Ethics
Monge’s mission is to ensure it manufactures its products in full compliance with its corporate commitment to safeguarding products, health, ethical conduct, employee safety, the environment, and energy. The Monge management considers the Integrated Policy as its main tool to manage its Quality, Environment, Health, Safety and Energy Management System, with a view to its continuous improvement.
Monge adheres to the ETI Base Code, which promotes good working practices.
The Monge Group is Italy’s leading manufacturing industry in the dry and wet pet food sector for dogs and cats.
Founded by Baldassarre Monge in Monasterolo di Savigliano (CN), in 1963, Monge was the first company in Italy to produce wet pet food. Today, the Group operates in over 80 countries worldwide and is the industrial partner of many market leaders, especially in the retail and grocery sector.
The company has always been strongly committed to its product; selecting raw materials of the highest quality, and applying the strictest standards of hygiene, safety, quality and environmental protection throughout the entire production cycle.
The Group has grown over the years, thanks not only to the strategic vision of the three generations of the Monge family who work there every day, but also the engagement and efforts of all its employees and collaborators.
All working together to create the Italian pet food family and pursue business objectives that align fully with our core values: respect and responsibility, integrity and seriousness, passion for research and innovation, and an underlying desire to offer an excellent product that guarantees animal welfare.
Developments over recent years have meant that today the Monge Group operates in a variety of rapidly and continuously evolving environments. The purpose of this document is to reaffirm the Group’s ethical vision and clearly express the principles and values that it recognises and shares.
However, the purpose of this Code of Business Conduct and Ethics is not only to set down established guiding principles, but also to create guidelines that help us make decisions and take actions that are consistent with a culture of responsibility, legality and transparency, in order to create long-term value for the Monge Group and all its stakeholders.
It also formalises the Monge Group adherence to standards and good practices set out in the initiative promoted by the Ethical Trading Initiative. The ETI is an association of companies, trade unions and voluntary organisations that share a commitment to improving working conditions throughout the supply chain.
The Monge Group, in particular, strictly complies with, and actively applies, the nine basic principles set out as part of the initiative and set down in the Code (the ETI Code), according to which:
Employment must be freely chosen; workers have the right to organize and bargain collectively; workplaces must be safe and hygienic; child labour is prohibited; living wages are paid; working hours are not excessive; there is no discrimination; and no harsh or inhumane treatment is allowed. Regular employment is also provided.
The use of the ETI Code is voluntary, but the Monge Group fully implements its contents, aware that a healthy and peaceful working environment is a factor for success.
The ETI Code forms an integral part of the Code of Business Conduct and Ethics adopted by Monge S.p.A. and is attached hereto.
Compliance with this Code is of primary importance for the trustworthiness, reputation and image of the Monge Group, its correct functioning, fulfilment of customer expectations and, in general, for all those factors that can contribute to the success and future development of the business.
The Code of Business Conduct and Ethics is based on the essential principle of compliance with laws and regulations currently in force. It is therefore the duty of every member of the Monge Group, wherever they operate, to comply with its contents.
In the event of any discrepancy between the principles expressed in the Code and laws governing Italy or the country in which the Group operates, the most restrictive regulations shall always apply, whether those set out in the Code or those of the legal system in question.
The Code is addressed to administrative and management bodies, supervisory bodies, managers and employees of Monge & C. S.p.A. and its Italian and foreign subsidiaries and affiliates, as well as third parties/business partners (such as suppliers, consultants, representatives, business partners) who operate in name, on behalf, or in the interests of, Monge & C. S.p.A. and its subsidiaries/affiliates.
The principles laid down in this document represent the common values and mandatory prerequisites that shall guide the conduct and behaviour of all the above recipients of the Code in the execution of their duties.
The subsidiaries of Monge & C. S.p.A. receive and implement this document. If the specific regulatory and/or organisational nature of the subsidiary requires it to make changes to the present Code, these changes must, however, be in line with the guiding principles and rules of conduct and ethics set out in this Code of Business Conduct and Ethics.
The Board of Directors and the Oversight Body (set up pursuant to Article 6 of Italian Legislative Decree No. 231, dated 8 June 2001) shall each exercise their function to guarantee that Monge & C. S.p.A.:
circulates, to the best of its ability, the Code among employees and collaborators; keeps the contents updated; and carries out adequate checks in the event of alleged violations of the Code.
Every employee or collaborator of Monge & C. S.p.A. and its subsidiaries/affiliates has a duty to be familiar with the rules contained in the Code and is required to:
refrain from any behaviour that might contravene the provisions of the Code; report any information relating to violations of the Code that come to their attention to the Oversight Body; cooperate with the Oversight Body during audits and inspections carried out to monitor compliance with the Code; and refrain from undertaking any other type of initiative that might contravene the contents of the Code.
With regard to third parties working for, and on behalf of Monge & C. S.p.A. and its subsidiaries/affiliates, all employees must:
inform third parties adequately about the provisions of this Code; require third parties (including their employees, collaborators and sub-contracted parties) comply fully with the provisions of the Code while performing activities for, and on behalf of, Monge & C. S.p.A. and/or its subsidiaries/affiliates; and take the necessary measures in the event that third parties fail to comply with the provisions of the Code.
Monge & C. S.p.A. has set up the Oversight Body as per Article 6 of Legislative Decree No. 231 dated 8 June, 2001. The Body is responsible for carrying out the tasks and duties set out in the aforementioned provisions. The Body is also required to work with the administrative and management bodies to perform the following tasks:
supervise that the Code is complied with, examine reports of its potential violation, and promote any checks deemed necessary; disseminate and monitor knowledge of the Code among employees, and therefore propose setting up specific training; actively promote issuing guidelines or operating procedures to clarify the meaning of the content and principles set out in the Code, with a view to reducing the risk of its violation; and propose updates to the contents of the Code of Business Conduct and Ethics whenever deemed appropriate.
Monge & C. S.p.A., together with the Oversight Body, has set up, and made available, an appropriate channel of communication in order to facilitate the reporting of any infringement of the Code by anyone aware of any such infringement.
Compliance with the Code of Business Conduct and Ethics is an integral part of the employment relationship.
Compliance with the rules and principles contained in the Code are an essential part of the contractual obligations for employees of Monge & C. S.p.A. and its subsidiaries/affiliates, as well as external third parties, collaborators, professionals and self-employed workers.
Infringement of the principles and contents of the Code of Business Conduct and Ethics constitutes a breach of the employment relationship’s primary obligations or a disciplinary offence with all subsequent legal consequences. These may include the termination of the employment relationship itself (subject to the gravity of the offence) and/or compensation for any damages arising from the violation itself.
Sanctions will be applied consistently, uniformly and impartially, in proportion to the seriousness of the violation.
Compliance with the Code of Business Conduct and Ethics is an essential prerequisite for collaborators and third parties wishing to establish and/or maintain professional working relations with Monge & C. S.p.A.
The history of the Monge Group is a family history, with principles and values that have inspired the company on a daily basis since its creation.
How these values and principles are applied is a constantly evolving process that is governed by innovation and the increasing complexities that the Group faces as it grows.
This Code of Business Conduct and Ethics provides an opportunity to bring the latest updated version of all these values and principles together in a single document and to circulate them to all those concerned:
Every employee, consultant, supplier, long-term business partner, and anyone else who has dealings with the Monge Group is required to observe the ethical principles listed above.
A conflict of interest is a situation, or potential situation, in which a secondary interest of a person working in the Monge Group (and so, towards which this person has specific duties and responsibilities) tends to interfere (actual conflict) or might potentially interfere (potential future conflict) with the primary interests of the Group.
In carrying out their duties and responsibilities, Monge Group employees, and recipients of this Code in general, must refrain from engaging in activities that are not in the interests of the Monge Group.
The Group recognises and respects the right of individuals to participate in activities other than those carried out in the interests of the Group, outside the workplace and outside working hours, provided that such activities are permitted by law, compatible with the contractual obligations undertaken with the Monge Group and that they do not damage the image and standing of the Group.
The recipients of this Code are required to avoid all activities that are, or may appear, to be in conflict of interest with the Monge Group, that may interfere with the ability of the recipient to make decisions in the exclusive interest of the Group, and for which there is clear expediency.
They are also required to refrain from taking personal advantage of business opportunities that come to their knowledge in the course of their duties.
In the event of a conflict of interest, Monge Group employees are required to promptly notify their department head and Oversight Body, and refrain from carrying out any activities related to the conflict.
If a potential conflict is identified, the person concerned is required to notify the Oversight Body. The Body shall investigate the claim and submit its assessment to the management of the relevant department or, depending on the case, to the Board of Directors. These latter, in accordance with their powers, may authorise, or refuse to authorise, the carrying out of the activities.
The following are some (non-exhaustive) examples of what may constitute conflicts of interest:
the obvious or hidden involvement of the employee, or family members, in the activities of suppliers, customers or competitors; exploiting one’s position in the pursuit of interests that conflict with those of the Monge Group; using information acquired during the course of work for personal gain or for the benefit of third parties and, in any case, contrary to the interests of the Monge Group; performing work of any kind (manual or intellectual) for customers, suppliers, competitors or third parties, in such a way that is contrary to the interests of the Monge Group.
The Monge Group strives for excellence in terms of quality, and promotes health, safety and innovation to achieve total customer satisfaction.
To this end, it works day in, day out, collaborating with research bodies and accredited laboratories, to provide customers and their animals with products that meet the highest quality standards.
The Monge Group constantly adopts and implements a system of procedures that allow the Group to monitor and control:
a) raw materials;
b) the production process;
c) product distribution in accordance with current regulations and Group standards.
Specifically, Monge product quality and safety have always been:
To date, Monge & C. S.p.A. has adopted the following management systems:
The company has also obtained the following certification:
All raw materials used in production must meet a series of specific quality and safety requirements.
Procurement is carried out through qualified suppliers; checks are carried out throughout the production cycle by both internal laboratories that apply certified analysis methods and accredited external laboratories.
Monge & C. S.p.A. upholds the principle that responsible advertising can help consumers make appropriate and informed purchasing choices and understand the important role that correct healthy nutrition has in animal welfare.
The Monge & C. S.p.A. communication policy:
The market approach pursued by the Group shall not, and cannot, in any way undermine or hinder the above principles.
The Monge Group supports fair and transparent relations with all customers so as not to offer any of them unfair competitive advantages over their competitors.
The Group adopts specific policies according to the size, type, channel or commercial strategy of the customer in order to guarantee the best possible service to the end-consumer and avoid discriminatory practices.
Specifically:
In general, it is expressly forbidden for employees of the Monge Group, or persons acting in its name, or on its behalf, involved either directly or indirectly in offering, promising, requesting, paying or accepting money or other benefits, to behave in a way so as to obtain, or maintain, an unfair advantage in relation to the Group’s activities when dealing with third parties (representatives of public administration, persons in charge of a public establishment, or private individuals).
It is not permitted to make cash payments exceeding the limits set by relevant legislation, make payments in a non-traceable manner or to anonymous numbered accounts, or give money to persons other than those entitled to receive it.
Suppliers are selected in accordance with the principles of impartiality and independence and on the basis of objective requirements: quality; professionalism and reliability.
Monge & C. S.p.A. assesses, qualifies and monitors suppliers.
The lists of suppliers drawn up by the Company do not constitute grounds for excluding suppliers that are not included in the list, if any such companies can demonstrate to meet the necessary requirements to fulfil the expectations of the Monge Group.New supplier assessment
and qualification is carried out on the basis of supplier performance during the first three deliveries. Performance is assessed and quantified numerically according to the assessment criteria stipulated in a specific procedure.
Value is given to the relationship of trust that exists with the supplier, especially in the case of consultants or the services of a specialist,
In compliance with the provisions of this Code of Business Conduct and Ethics, the Monge Group requires its suppliers to:
The companies within the Monge Group do enter business relations with suppliers that do not accept these conditions. They therefore reserve the contractual right to take any appropriate measures (including contract termination) in the event that the supplier violates the law, contract, or provisions of this Code, while carrying out activities in the name and/or on behalf of a Monge Group company.
Relations with suppliers are governed by specific company procedures and subject to constant monitoring.
Employees and collaborators involved in procurement:
Relations with Public Administration, or relations involving public office in general, must be based on strict compliance with applicable laws and regulations and must not in any way compromise the integrity and reputation of the Monge Group.
Any kind of commitment to, or management of relations representatives of the Public Administration and/or public bodies are reserved exclusively for the persons, functions and departments responsible for such relations and authorised to do so.
In its relations and dealings, including commercial dealings, with the Public Administration, the Monge Group must not seek to improperly influence the decisions of the persons, body or institution concerned.
The Monge Group undertakes not to:
offer employment or commercial opportunities to public administration personnel – or their family members – involved in negotiating or relations with companies in the Group; offer gifts, either directly or through third parties, to public administration personnel, unless these gifts are of modest value and in line with standard commercial practices, and of such a nature that they cannot give rise (in the counterpart or in an unrelated and impartial third party) the impression that they are intended in any way to obtain an unfair advantage, exert unlawful influence on the activities and/or decisions of the other party, solicit, provide, or obtain, confidential information that compromises the integrity or reputation of the Group. Any gifts should be adequately authorised and documented.
In relations with the Public Administration in Italy or abroad, the recipients of this Code of Business Conduct and Ethics are not permitted to pay or offer (whether directly or through third parties) sums of money or gifts of any kind or amount to public officials, public service employees, government representatives, public employees or private citizens of countries with which the Monge Group has relations. Recipients of the Code must not compensate any of the aforementioned persons for an act of their office or for the purpose of speeding up, facilitating or simply ensuring the performance of a routine or otherwise lawful and legitimate activity in the exercise of their functions, nor to achieve the performance of an act contrary to the duties of their office.
Acts of courtesy, such as gifts or forms of hospitality, or other forms of generosity, are permitted if they are of modest value and do not compromise the integrity and reputation of the parties concerned, and cannot be interpreted by an impartial third party as acts intended to obtain an improper advantage or favour. Such acts of courtesy must always be authorised and adequately documented.
Relations between the Monge Group and the mass media in general are the exclusive responsibility of the persons or departments expressly delegated to do so. Relations must be conducted in accordance with the communications policy defined by the Board of Directors or, where applicable, by the management of the department concerned.
Only employees who have received specific training and authorisation may represent the Group in public and in the media.
Information and communications relating to the Monge Group and intended for external use must always be accurate, truthful, complete, transparent and consistent.
All persons who are invited, in the name, or on behalf, of the Monge Group, to participate in conferences, congresses or seminars, or to write articles, essays or publications in general, are required to obtain prior authorisation from the relevant departmental management or from the Board of Directors regarding the content, reports, and any other documents, prepared for this purpose.
Relations between the Monge Group and the mass media in general are the exclusive responsibility of the persons or departments expressly delegated to do so. Relations must be conducted in accordance with the communications policy defined by the Board of Directors or, where applicable, by the management of the department concerned.
Only employees who have received specific training and authorisation may represent the Group in public and in the media.
Information and communications relating to the Monge Group and intended for external use must always be accurate, truthful, complete, transparent and consistent.
All persons who are invited, in the name, or on behalf, of the Monge Group, to participate in conferences, congresses or seminars, or to write articles, essays or publications in general, are required to obtain prior authorisation from the relevant departmental management or from the Board of Directors regarding the content, reports, and any other documents, prepared for this purpose.
The Monge Group is favourable to non-profit activities and initiatives of ethical, legal and social value in the communities where the company works and operates.
In compliance with the principles established in this Code, activities of non-profit associations with regular statutes and articles of association that are of a high cultural or charitable value may be promoted.
Monge Group sponsorship may concern fields ranging from social events, to sports, entertainment, art and culture. However, the events in question will always provide a guarantee of high value.
Sponsorships are authorised by the Board of Directors or by the departmental management directly concerned, after having assessed the nature of the event and to whom it is addressed.
The Monge Group will pay close attention to any potential conflicts of interest, whether personal or corporate, when choosing which proposals to accept.
Gifts and gratuities that exceed reasonable limits or that are inconsistent with normal working relations may create situations of influence and therefore interfere with the normal conduct of working relationships.
The benchmark used by the Monge Group to assess what may be considered reasonable as a value of a gift or gratuity is indicated by the National Anti-Corruption Authority, ANAC (where the value of a gift should not exceed €150 or, cumulatively, €600 per year in the case of gifts made by the same person or company).
The Monge Group firmly prohibits employees and collaborators from offering money, gifts or benefits of any kind to third parties in order to obtain undue personal advantage or advantages for the companies within the Group.
Specifically, any gifts, hospitality or entertainment expenses offered to public or private bodies must, regardless of the circumstances:
The Monge Group prohibits employees and family members from accepting and requesting, for themselves or others, gifts, benefits or favours offered by persons with whom they have working relations, which could compromise their independence of judgement or at least raise the suspicion that such independence has been compromised.
Benefits may be considered both tangible goods (such as travel, watches, jewellery, fine wines, mobile phones, hi-tech devices, valuable items, etc.) and services and discounts on purchases of goods or services.
Small gifts such as flowers, gadgets, books, sweets, etc. are considered standard business courtesies.
Any invitations to lunch or dinner must never overstep what can be considered to be correct professional relationships and must always maintain separate personal and working relationships.
Every operation or transaction carried out by Monge Group companies must be correctly recorded in the company accounting system in accordance with legislation in force and applicable accounting standards. Transactions and operations must always be authorised, verifiable, legitimate, consistent and appropriate.
In order for company accounting to meet these requirements, adequate and complete supporting documents must be kept on file for each accounting entry for each corporate transaction, so as to allow:
Every employee and every company department is responsible for the truthfulness, authenticity and originality of the documentation and information processed.
It is the responsibility of all Monge Group personnel involved in accounting procedures to ensure that supporting documents are easily accessible, organised logically, easily consultable, and can be promptly presented upon request by supervisory bodies or competent authorities.
Anyone aware of omission, falsification or negligence in accounting records or supporting documents is required to report this promptly to the Oversight Body.
‘Internal controls’ refers to the set of rules, procedures and organisational processes designed to enable the company to be run in a sound and proper manner, and in line with its objectives, by adequately identifying, measuring, managing and monitoring the main risks. These controls help to safeguard the company assets, ensure the reliability of financial information and ensure compliance with laws and regulations as well as the internal procedures adopted by the Monge Group.
It is the responsibility of Monge & C. S.p.A. to raise awareness of the existence of internal controls and the need to exercise of such controls throughout, and at every level of, the organisation.
The heads of the various departments are required – within the scope of their responsibilities – to participate in setting up, and implementing, an effective corporate system of controls, and to involve their subordinates in this process.
The employees of the Monge Group companies are therefore required – within the scope of their responsibilities – to:
The Board of Statutory Auditors, the company responsible for auditing the accounts, the Oversight Body, and the entities/companies that carry out auditing activities have free access to data, documentation and any information deemed useful in order to carry out their control activities.
Money laundering refers to replacing or transferring money, goods or other benefits gained illicitly, or carrying out operations aimed at making the illegal/criminal origins of these proceeds difficult to identify.
Financing terrorism refers to the direct or indirect provision or collection of funds by any means, with the intention, or knowledge, that they are intended to be used for terrorist-related purposes.
The use of unlawfully gained revenue refers to the use of money, goods or other assets deriving from criminal activities in lawful, economic, or financial activities.
The Monge Group:
The company’s human resources are an essential part of how the company performs its activities and for the future development of the Monge Group companies.
In order to ensure that the skills and competences of employees and collaborators are given due value, so that everyone can express their potential, each company department must:
Employees of Monge Group companies must be aware of the provisions of this Code of Business Conduct and Ethics and the conduct it prescribes. Meetings are held to raise awareness of these provisions and disseminate relevant information.
The Monge Group is committed to respecting the personality traits of their employees, protecting their mental and physical wellbeing, and ensuring that they are not subjected to undue influence or discomfort.
With a view to this, and to protecting its image and reputation, the Monge Group reserves the right to consider relevant any behaviour outside work which, due to its resonance, is considered offensive to the company or its employees, and will intervene to protect against abusive or defamatory behaviour.
Employees are therefore required to cooperate in maintaining a corporate climate of mutual respect and not to adopt any attitude that may damage the dignity, honour and reputation of others.
The Monge Group guarantees equal opportunities to all its employees, regardless of level, and forbids any form of discrimination or harassment in internal and external work relations (e.g. creating a hostile working environment for individual workers or groups of workers, unjustified interference in the work of others, or interfering in the potential professional development of others).
The Group companies compensate and promote their employees using solely the results of their work as a benchmark.
The Group favours and aims to create a corporate climate of tolerance and respect for human dignity. As such, it prohibits:
The Monge Group does not tolerate sexual harassment, defined as the subordination of professional/career growth opportunities, or benefits for the provision of sexual favours, as well as any other behaviour of a sexual nature or based on gender which is unwanted by one of the parties and harmful to a person’s dignity.
The Monge Group is committed to ensuring the health and safety of employees and collaborators. It has therefore banned smoking in the workplace, even where this is not prohibited by national legislation.
Anyone working for the Monge Group is required to contribute to maintaining a climate of mutual respect in the workplace and to pay particular attention to protecting their own safety and that of their colleagues.
It is strictly forbidden for all employees and collaborators to:
Chronic alcohol and drug addiction that affects work performance and that may disrupt the normal working day activities will be treated in the same way as the above cases.
The Monge Group is constantly committed to improving the environmental performance of its activities while paying close attention to the safety and quality requirements of its products.
When implementing structural and technological changes, the Group takes into account the environmental impact that these changes may have.
Specifically, the companies of the Monge Group:
In addition, when carrying out their daily activities, employees of Monge Group companies are required to:
Confidential information:
The recipients of this Code may, as a result of their role and position within the Monge Group, come into possession (directly or indirectly) of confidential information concerning the Group companies.
The corporate knowledge and expertise represents a strategic component of the Group’s corporate assets. Each recipient of this Code is required to protect this knowledge by ensuring confidentiality and privacy.
Specifically, all information, knowledge and data acquired or processed by Monge Group employees while carrying out their duties belongs to the Monge Group and may not be used, communicated or disclosed without prior and specific authorisation.
Employees and collaborators are required to:
Employees and collaborators are prohibited from:
IT tools are essential in order for Monge Group companies to carry out their activities.
Employees and collaborators are required to comply with the security policies adopted for the use of IT systems, and not to:
Telephone systems, and access to e-mail, the Internet and the Intranet belong to the Group companies.
The use of the telephone, email and the Internet in the workplace must be for legitimate professional purposes and comply with the level of authorization granted to each person.
It is the responsibility of each employee and collaborator to keep the access credentials and identification codes they have received confidential in order to prevent unauthorised access to company data and information.
Only products officially purchased by the Group company where the employee or collaborator who receives them works, or authorised by the IT Manager of Monge & C. S.p.A., may be installed and used on computers and, in general, on company IT equipment.
Reproducing or copying software programmes is strictly prohibited: any employee or collaborator who knowingly or unknowingly copies software material puts the company and themselves at risk of severe penalties.
All employees and collaborators are also required to:
In accordance with the Organizational Model for Management and Corporate Governance, and company procedures regarding the use of IT tools, the following are not permitted:
When carrying out their activities, Monge Group companies process a significant amount of personal data and information relating, for example, to employees, collaborators, customers and suppliers.
Monge Group companies undertake to acquire only the data necessary to achieve the purposes for which it is collected, and to process it in compliance with laws currently in force regarding personal data protection and confidentiality of information. It is prohibited to use, communicate or disclose personal information improperly.
The Monge Group ensures that all processing is carried out lawfully, fairly, correctly and transparently, so that personal data is only processed for specific, clear and legitimate purposes. The Group undertakes to adopt the necessary technical and organisational security measures.
All employees and collaborators are required to:
Any personal comments on social media or social networks must be made with respect for other people (such as colleagues, customers, suppliers, etc.) and their privacy, as well as for company values, without limiting the opinions expressed or content posted.
Should this not be the case, the author, and consequently the Monge Group, may be exposed to legal, social or reputational risks.
All employees and collaborators should keep their private life and work and role representing the company separate.
Specifically:
Monge & C. S.p.A. has adopted the Organizational Model for Management and Corporate Governance referred to in Article 6 of Legislative Decree No. 231 dated 8 June 2001. This Model is a comprehensive set of principles, rules and regulations aimed at preventing offences from being committed which may (according to the same Legislative Decree) involve the Company’s liability. The General Guidelines of the document are provided below.
EUROPEAN UNION AND NATIONAL LEGISLATION GOVERNING WHISTLEBLOWING PROCEDURES AND VIOLATION REPORTING; ITALIAN LEGISLATIVE DECREE NO. 24 DATED 10 MARCH, 2023, LAYING DOWN DIRECTIVE (EU) 2019/1937
In compliance with Legislative Decree No. 24 dated 10 March, 2023, Monge & C. S.p.A. has set up an internal reporting channel for violations. The channel uses encryption tools to guarantee the confidentiality of the identity of the person making the report, the person involved, any persons mentioned in the report, as well as the content of the report and related documentation.
The reporting channel is managed by the Oversight Body.
The whistleblower may report the alleged violation to the Oversight Body of Monge & C. S.p.A. using one of the following methods:
1. in writing via an encrypted platform, which can be accessed at the following link
2. orally, by requesting a face-to-face meeting with the Oversight Body within 10 days, subject to appointment. The violation report is documented (either by recording on a storage device suitable for playback, or written minutes) by the Oversight Body with the consent of the whistleblower during the meeting. In the case of written minutes of the meeting, the whistleblower may verify, correct and confirm the minutes by signing them.
Should a member of the Oversight Body be involved, the whistleblower may use other forms of reporting, complaint or public disclosure provided for by the Decree. In particular, the whistleblower may contact ANAC directly through the reporting channel made available by ANAC. This can be accessed via the following link: https://whistleblowing.anticorruzione.it/#/
Violation reports may be made by:
Whistleblower protection applies in the following cases:
Conduct for which a report may be made includes:
These include:
| Product safety and compliance; |
| Food and feed safety, animal health and wellbeing; |
| Transport safety; |
| Public health; |
| Environmental protection; |
| Consumer protection; |
| Public procurement tenders and contracts; |
| Financial services, products and markets, and the prevention of money laundering and terrorism financing; |
| Privacy and personal data protection, network security, and IT system protection. |
In order to enable the Oversight Body to carry out the necessary checks, the person reporting the violation shall provide as much detail as possible.
The report must in any case specify:
Documents to support the facts in the report can be attached, as well as details of other people who might know have information regarding the facts.
Non-specific statements, information that is already public knowledge, or information based on third-party hearsay shall not be accepted or taken into consideration.
Any anonymous reports will be checked for legitimacy and that they are based on facts. Specifically, Monge & C. S.p.A. will only consider anonymous reports when they are adequately detailed and provide sufficient information to highlight facts and circumstances occurring in specific contexts (e.g. indication of names or specific roles/titles, mention of specific offices, procedures or events, etc.).
Monge & C. S.p.A. has set up an Oversight Body composed of a single member, pursuant to Article 6 of Legislative Decree No. 231 dated 8 June, 2001.
Oversight Body email: odv@monge.it.