Our system of reporting unlawful behavior - "Whistleblowing"

Gas and Heat S.p.A. is committed to promoting a corporate culture based on ethical behavior and good corporate governance, thereby fostering an environment in which People are encouraged to report unacceptable conduct within our organization.
For this reason, Gas and Heat has specific channels, processes and procedures in place to ensure confidentiality and the absence of retaliatory acts for people who report unlawful behaviour.
Violations and/or irregularities related to the issues covered in the attached Whistleblowing Policy and external regulations may be reported.
More specifically, by way of example but not limited to:
  • Corruption;
  • Money laundering;
  • Violation of Financial Sanctions regulations;
  • Violation of antitrust laws;
  • Insider trading and/or market manipulation;
  • Harassment;
  • Bullying;
  • Fraud;
  • Misuse of confidential customer and Company data;
  • Violation of the Code of Ethics and/or Code of Conduct;
  • Violations of the Organization and Management Model pursuant to Legislative Decree 231/01.
Reports should be submitted through the use of one of the following channels:
By sending an email to the following address: 
By sending a written report marked "CONFIDENTIAL"/"PERSONAL" by mail or by hand addressed to:
OdV Gas and Heat Spa C/O registered office of the same company, indicating an address, i.e., a mobile address, in order to handle the report
Orally, by contacting 0586.880649, requesting a telephone appointment with the Supervisory Board of Gas and Heat Spa.
The indicated channels cannot be used to propose a complaint related to the business relationship, but only to report illegitimate behavior.
It should be noted that in Italy, in implementation of Legislative Decree 24/23, the National Anti Corruption Authority (ANAC) was identified as the authority responsible for receiving and handling external reports, albeit anonymously.
The Reporting Person may then make an external report to ANAC if, at the time of its submission, one of the following conditions is met:
  • There is no mandatory activation of the internal reporting channel within its work context, or it is not active or, even if it is activated, it does not comply with the requirements of the law;
  • He has already made an internal report and it has not been followed up;
  • He has reasonable grounds to believe that if he made an internal report, it would not be effectively followed up or that the report itself might result in a risk of retaliation;
  • He has good reason to believe that the violation may constitute an imminent or obvious danger to the public interest.
  • In addition, the Reporting person can also turn to ANAC to notify any retaliatory acts resulting from a report.

External reports to ANAC can be made in the manner provided on the institution's institutional website.

Download the forms

Download the reporting form and Privacy Policy

Download the procedure