Criminal Compliance Policy

The ODILO Whistleblowing Channel is a tool provided by ODILO and/or related entities (hereinafter jointly referred to as “the Organisation”) to enable the reporting of any possible irregular or illegal behaviour within the Organisation that may constitute a breach or violation of the Code of Conduct, the Organisation’s internal policies and/or any applicable legal regulations.

The ODILO Whistleblowing Channel is managed by i2Ethics, an independent external company specialising in communications management, which provides the Channel’s web platform and interacts with both whistleblowers and ODILO’s compliance officers, in order to communicate any reports of possible irregular or illegal behaviour within the Organisation that may constitute a breach or violation of the Code of Conduct, the Organisation’s internal policies and/or any applicable legal regulations.

i2Ethics is responsible for providing and maintaining the channel so that it is accessible and highly available to users, guarantees the confidentiality of communications received, safeguards data with the highest possible security and archives all data in accordance with current regulations, and advises on the relevance of such data and on good practices in the management of a communications channel.

The ODILO Whistleblowing Channel:

• Guarantees the absolute confidentiality of the Whistleblower’s data. All persons who, for reasons related to the investigation, need to know its content are subject to a confidentiality agreement.
• ODILO will not tolerate any form of retaliation against the whistleblower or those who collaborate in the investigation.
• False or malicious communications will be subject to disciplinary measures.
• It is the responsibility of employees to cooperate proactively with investigations resulting from communications received.
• The use of an external platform for managing communications guarantees the anonymity of the Whistleblower if the Whistleblower so prefers.

The Reporting Channel will be available to all ODILO employees and former employees, current and potential suppliers and their employees, ODILO executives, customers, and anyone who has a connection with ODILO and direct knowledge of the facts to be reported.

Access to the Channel: https://odilo.i2-ethics.com