Whistleblowing Policy

Reporting System

In implementation of Directive (EU) 2019/1937, it was issued Legislative Decree No. 24 of March 10, 2023 on “the protection of persons who report breaches of Union law and laying down provisions concerning the protection of persons who report breaches of national regulatory provisions”.

The Whistleblowing process makes it possible to report violations that harm the public interest or the integrity of 130 Servicing SpA (the “Company”) that have come to one’s attention within the work context while protecting the reporter from possible retaliatory or discriminatory behavior.

Through the reporting system it is, therefore, possible to report facts, behaviors or omissions that constitute a violation of national and European Union regulations, including well-founded suspicions, that harm the public interest or the integrity of the Company.

Unsubstantiated news, information that is already totally in the public domain, as well as information acquired only on the basis of rumors or poorly reliable will not be considered.

The reporting system guarantees adequate protection for the reporter, ensuring the protection of the confidentiality of the reporter himself/herself, the persons involved and the persons in any case mentioned in the report, as well as the content of the report and related documentation.

Any personal data contained in the report will be processed in accordance with the data protection regulations and the GDPR Policy adopted by the Company.

For the Privacy Policy, please refer to the relevant section of the menu of this software “EQS Integrity Line”.

For more information on the reporting system, please refer to the Guidelines available in the “Whistleblowing Guidelines” box inside .

Reports of potential misconduct in EU member states or identified by whistleblowers within the EU can also be reported to external authorities.

What can be reported?

Information on violations, including well-founded suspicions, of national and European Union regulations that harm the public interest or the integrity of 130 Servicing Spa (the “Company”) is subject to reporting. Information on violations may also cover those not yet committed that the reporter, based on concrete elements (such as irregularities and anomalies that may give rise to a violation), believes could be committed. In addition, elements concerning conduct aimed at concealing such violations, such as concealing or destroying evidence about the commission of violations, may also be reported.

Violations may concern both national and European Union regulatory provisions.

The provisions of the Decree do not apply to disputes, claims or demands related to an interest of a personal nature that relate exclusively to individual labor relations, i.e., labor relations with hierarchically subordinate figures.


This category includes criminal, civil, administrative or accounting offenses that constitute a violation of national statutory and regulatory provisions. This includes predicate offenses under Legislative Decree 231/2001 and violations of the Organizational Model adopted by the Company.


These are:

  • offenses that fall within the scope of application of European Union acts and national provisions implementing them, relating to the following areas: public procurement; services, products and financial markets and prevention of money laundering and financing of terrorism; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and personal data protection and security of networks and information systems;
    • acts or omissions affecting the financial interests of the Union protected under Article 325 TFEU (fraud, corruption or illegal activities related to Union expenditure);
    • acts or omissions affecting the internal market as referred to in Article 26(2) TFEU, including violations of EU competition and state aid rules as well as  corporate taxes or mechanisms whose purpose is to obtain a tax advantage that nullifies the object or purpose of the applicable corporate tax law;

acts or conduct that nullifies the object or purpose of the provisions set forth in EU acts in the areas listed above.