In compliance with Legislative Decree No. 24/2023 and with particular reference to Legislative Decree No. 231/2001, we inform you that as of 19/12/2023, our Company has adopted the “Whistleblowing” tool.

More specifically, Whistleblowing is an additional corporate compliance tool, through which employees, collaborators or third parties (e.g. a supplier or a customer) of a company may report, in a confidential and protected manner, any wrongdoing encountered during their activities.

To this end, a dedicated portal has been set up to receive reports that can be made completely ANONYMOUS, as expressly provided for in the aforementioned legislation.

The report can be made using the channel available by accessing the link:

on the Company’s institutional website.

On first access, log in with ID: reporter_dmm and PASSWORD: reporter_dmm

Watch the educational video on YouTube


Behaviour, acts or omissions that harm the public interest or the integrity of the public administration or private entity and that consist of

– administrative, accounting, civil or criminal offences;

– unlawful conduct within the meaning of Legislative Decree 231/2001, or violations of the organisation and management models provided for therein

– offences falling within the scope of application of European Union or national acts relating to the following areas: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; 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; protection of privacy and protection of personal data and security of networks and information systems

– acts or omissions affecting the financial interests of the Union;

– acts or omissions affecting the internal market;

– acts or conduct that frustrate the object or purpose of the provisions of Union acts.



The following are excluded from the application of this legislation:

– objections, claims or requests linked to an interest of a personal nature of the reporting person or of the person making a whistleblowing report to the judicial authority that relate exclusively to his or her individual work or public employment relationships, or inherent to his or her work or public employment relationships with hierarchically superior figures (therefore, excluded are, for example, reports concerning labour disputes and pre-litigation phases, discrimination between colleagues, interpersonal conflicts between the reporting person and another worker or with hierarchical superiors, reports concerning data processing carried out in the context of the individual employment relationship in the absence of injury to the public interest or to the integrity of the public administration or private body);

– Reports of breaches where they are already mandatorily regulated by the European Union or national acts indicated in Part II of the Annex to the Decree or by national acts constituting the implementation of the European Union acts indicated in Part II of the Annex to Directive (EU) 2019/1937, although not indicated in Part II of the Annex to the Decree;

– national security breaches, as well as procurement relating to defence or national security aspects, unless such aspects are covered by the relevant secondary legislation of the European Union.



– internal;

– external (managed by A.N.A.C.);

– public disclosure (through the press, electronic media or media capable of reaching a large number of people);

– reporting to the judicial or accounting authorities.


Whistleblowers may use the external (ANAC) channel when

– there is no mandatory activation of the internal reporting channel within the work context, or this channel is not active or, even if activated, does not comply with the requirements of the law

– the reporting person has already made an internal report and it was not followed up;

– the reporting person has reasonable grounds to believe that, if he/she were to make an internal report, it would not be effectively followed up or that the report might give rise to a risk of retaliation;

– the reporting person has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest;

Whistleblowers may directly make a public disclosure when:

– the reporting person has previously made an internal and external report, or has made an external report directly and no reply has been received within the prescribed time limits on the measures envisaged or taken to follow up the reports;

– the reporting person has justified reason to believe that the breach may constitute an imminent or obvious danger to the public interest;

– the reporting person has justified reason to believe that the external report may entail a risk of retaliation or may not be effectively followed up by reason of the specific circumstances of the case, such as where evidence may be concealed or destroyed or where there is a well-founded fear that the recipient of the report may be colluding with or involved in the perpetrator of the breach.



– At the time of the report or denunciation to the judicial or accounting authorities or public disclosure, the reporting or denouncing person must have a reasonable and well-founded reason to believe that the information about the violations reported, publicly disclosed or denounced is true and falls within the scope of the legislation


– Reporting or public disclosure must be made using the channels provided (internal, external and public disclosure) according to the criteria indicated).

More information in relation to ANAC’s competences is available by accessing the aforementioned Authority’s website ( in the appropriate section).


ANAC has provided for sanctions ranging from €500 to €2,500 for whistleblowers in the event that the whistleblower is found to be criminally liable for the offences of defamation or slander.


/////// da capire se va messa …. Molto non lo fanno … ha anche un costo a livello di sito  //////

Aggiungere una frase in cui il segnalante può accedere al link di segnalazione solo dopo aver cliccato (es. “I fully understand the above and intend to proceed with the report”)