Whistleblowing

Internal Procedure

In compliance with current regulations, and in particular with Legislative Decree 24/2023, Milestone has adopted an IT platform that allows you to report (including on an anonymous basis) any criminal, civil, administrative or accounting offences you notice in the workplace, as well as breaches of the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 and the Code of Ethics (Embracer Group Code of Conduct), where said events damage the public interest or the company‘s interest. The breach may not, however, concern a personal interest related solely to your relationship with the company.

In particular, the following persons may report the offences described above:

  • Employees (including those in probationary period);
  • Self-employed workers and co-workers;
  • Employees or co-workers of the company’s suppliers;
  • Freelancers and consultants working for the company;
  • Volunteers and interns, whether paid or unpaid, who perform tasks on behalf of the company;
  • Shareholders and persons with administrative, management, control, supervisory or representative functions in the company;
  • Candidates and potential suppliers.

Milestone guarantees to protect the person filing the report in full, safeguarding:

  • his or her identity, and the events being flagged, as well as the identity of the persons concerned in the report and the reputation of third parties in cases where the claim proves unfounded. The platform is accordingly the preferred means of sending and managing any reported events, as it is designed to protect such information with the necessary IT tools. The identity of the whistleblower will remain confidential, and his or her data will be accessible solely and exclusively to the person in charge of handling the whistleblowing channel, unless the whistleblower him/herself gives his or her express consent, or disclosure becomes necessary due to legal proceedings.
  • the whistleblower against any retaliatory and discriminatory behaviour taken against them for reasons directly or indirectly related to the reported event and which affect the conditions of the whistleblower’s relationship with Milestone.

As part of the process involved in managing any events which are flagged, personal data are processed in compliance with the relevant legislation in force (EU Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018). Any documentation and data related to the reported events will be kept for the amount of time deemed strictly necessary for processing the report, and in any case no more than 5 years after the final outcome of the procedure has been notified.

The report must be made in a professional manner and in good faith, and only if there is good reason to believe that the information concerning the breaches is true.

If it is found that the whistleblower has filed a deliberately false report, the whistleblower may be liable to be sued for libel or slander and a disciplinary penalty and/or fine may be imposed.

The event should be reported:

  • Preferably in written form, using the relevant corporate platform (https://report.whistleb.com/message/milestoneitaly);
  • Orally, requesting a meeting with the manager in charge of handling the whistleblowing channel, namely the Head of Human Resources Dr. Lucia Cappelli. The meeting will be scheduled within 7 days of the request being made;
  • Alternatively, by sending an email to the address provided for flagging events involving breaches of the Organisational Model 231/2001 as soon as it comes into force.

The content of the report can take any form, but it is important that as much information as possible is provided to facilitate internal enquiries.

Within 7 working days, the person filing the report will receive confirmation that it is being handled by the person in charge of the whistleblowing channel. Within 3 months of receiving the report (during which the manager of the whistleblowing channel may also request additional information), the person filing the report will be given feedback.

If this should not happen, or if the reporting person has reasonable grounds to believe that use of the internal reporting channel may result in the report not being effectively followed up. or indeed pose the risk of retaliation, ANAC’s external whistleblowing channel – Whistleblowing – www.anticorruzione.it – may be used instead.