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SEA believes that compliance with the ethical principles that inspire its work is essential, particularly by all its stakeholders. These principles have been identified, inter alia, in the Code of Ethics approved by the Board of Directors; similarly, SEA believes that compliance with all applicable regulatory provisions is essential. In this perspective, the Company has implemented a system for the management of reports on illicit facts or facts contrary to the above mentioned ethical principles (the so called "Whistleblowing") which consists of an IT platform whose technical support is entrusted to a primary operator in the sector for sending reports by all parties involved (employees and collaborators of the Companies, consultants, suppliers and any other third party who has a relationship or carries out activities on behalf and/or in the interest of SEA).
The platform guarantees the confidentiality of the personal data entered and the content of the reports, in particular, the personal data and the identity of the whistleblower, without prejudice to any legal obligations.
SEA also undertakes to comply with the applicable legislation currently in force on the protection of personal data.
The platform is located on a site outside SEA and access is not tracked.
How to access the platform
The whistleblowing platform is accessible with a browser such as Google Chrome or Internet Explorer version 10 or higher, at the following link: Whistleblowing SEA
Upon access, the whistleblower must first select the Company for which he/she intends to send the report (SEA, SEA Prime), then proceed according to the instructions proposed in the platform.
At the end of the filling process, the platform will release a code - no longer available after the report has been sent - to be kept by the whistleblower; this code will allow only the whistleblower to check the status of the report at any time and to communicate to the relevant entity any further information or documents that may be useful for establishing the facts reported.
What to report and whom to direct the report
Reports may be sent to one of the following relevant entities - each having a distinct access channel on the platform - in relation to the specific content of the report:
- Ethics Committee:
For reports of conduct in violation of the Code of Ethics (e.g.: alleged bribery, conflicts of interest, misuse of company assets or negligence in their use). For the complete case history, refer to the SEA Code of Ethics at the following link
- Supervisory Board:
For reports relating to the alleged commission of crimes covered by Legislative Decree 231/2001 (e.g.: environmental crimes, violations of health and safety regulations in the workplace, crimes against the State or other public bodies, etc.) or for failure to comply with company procedures. For a complete list of the offences identified by Legislative Decree 231/2001, refer to the Organisation and Management Model pursuant to Legislative Decree 231/2001 SEA - General Section, at the following page link
The relevant bodies listed above (Ethics Committee and Supervisory Board) rely on the Auditing Department for the investigation of the received reports managing process.
- Auditing:
For procedural violations, fraud, non-compliance with contractual clauses and for any reports not falling within the area of responsibility of the above mentioned bodies.
- Director of the Control, Risk and Sustainability Committee:
Exclusively in cases in which the report relates to conduct by the Auditing management of SEA or in cases in which Auditing has an interest, even if potential, in relation to the facts reported, such as to compromise impartiality and independence of judgement.
- For commercial or operational communications (e.g.: complaints, commercial information, etc.), other dedicated channels are available and indicated on the Company's website.
Confidentiality on the identity of the whistleblower and the content of the reports
The report shall be managed by the responsible bodies so that the confidentiality of personal data and the content of the report is guaranteed, in particular, the identity of the whistleblower who, if declared, will not be disclosed, except in cases provided for by regulatory provisions.
During the fact finding procedure related to the report, every right of the whistleblower is guaranteed and, in no case, proceedings will be initiated against him/her in the absence of concrete evidence on the truthfulness and validity of the report. The whistleblower will be protected at all times, both during the reporting process and afterwards, from the possibility that sanctions, discriminatory measures, retaliation of any kind, directly or indirectly resulting from or related to the report made, are directed against him/her. In particular, where the whistleblower is an employee of the Company outside the cases of liability for malicious intent or gross negligence or outside the cases of slander or defamation or also in cases of reports made in bad faith, the application of any discriminatory, disciplinary and/or retaliatory sanctions or measures, directly or indirectly connected to the report, is expressly prohibited. SEA expressly reserves all action to protect its interests, both direct and indirect, in the event of reports made in bad faith or defamatory or slanderous, which may cause damage or prejudice of any nature to its employees, members of its corporate bodies or third parties in business relations with the Company. The disciplinary system of SEA provides for sanctions for those who make intentional or grossly negligent reports that prove to be untrue or unfounded.
To access the platform use a browser (Google Chrome or Internet Explorer version 10 or higher)