Whistleblowing Notice
(Article 5(1)(e), Legislative Decree No. 24 of 10 March 2023)
 
Pursuant to Article 5(1)(e) of Legislative Decree No. 24 of 10 March 2023, implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, and laying down provisions on the protection of persons who report breaches of national laws and regulations, OUR FILMS S.p.A., with registered office at Via Giovanni Nicotera no. 29, 00195 – Rome, VAT No. 17506111008 (hereinafter, the “Company”), provides its employees, collaborators, self-employed professionals, consultants and shareholders (the “Reporting Persons”) with information regarding the channels, procedures and conditions for reporting misconduct adopted by the Company, as well as information concerning the external reporting channel established by the Italian National Anti-Corruption Authority (ANAC).
 
 
Internal reporting channel
The Company, which is part of the Mediawan Group, encourages the submission of reports through the dedicated electronic channel / IT platform “EQS Integrity Line”, provided by EQS Group AG and made available to the Company by Mediawan SAS (46 avenue de Breteuil, 75007 – Paris), accessible at the following link: “Mediawan | Home” (the “Internal Channel”).
Reports may be submitted by following the authentication procedure provided on the platform.
The Internal Channel is available at all times (24/7, 365 days a year), without prejudice to updates or technical issues that may result in temporary unavailability.
In order to ensure the security of the information and data included in the reports, the Internal Channel, inter alia:
implements encryption techniques (so as to render the data unintelligible to unauthorised persons), applicable both to data in transit and data at rest;
provides for multi-factor authentication procedures;
has obtained security certifications in line with best market standards (e.g. ISO 27001 and ISAE 3000 Type II / SOC 2).
Reporting Persons retain the right to submit reports also by:
registered letter with return receipt, addressed to the Internal Whistleblowing Officer, at the Company’s registered office; and
certified email (PEC) sent to ourfilmsspa@pec.it.
 
 
whistleblowing policy
The Company has also adopted a specific procedure (the “Whistleblowing Policy”) governing the reporting of unlawful conduct (so-called “compliance concerns”).
The Whistleblowing Policy, inter alia, provides for:
a definition of the scope of reportable concerns, referring to facts or conduct that may constitute:
criminal or civil offences, such as fraud, misappropriation, unauthorised disclosure of confidential information relating to the Company or the Mediawan Group, discrimination and harassment, corruption, extortion, trading in influence, damage to electronic communications networks and systems, and breaches of applicable data protection laws;
a serious threat to, or harm affecting, the public interest, including matters relating to health, safety or the environment;
a breach of the Mediawan Group’s code of conduct;
the availability of the Internal Channel (see Section 1), managed through an external and secure platform provided by an independent service provider, separate from the Company’s and the Mediawan Group’s websites and intranet systems;
the possibility for Reporting Persons to interact with the person responsible for handling reports (the Referee), including for the purpose of providing clarifications or additional information during the assessment and investigation phase, in accordance with the procedures set out in the Whistleblowing Policy;
specific safeguards concerning confidentiality, in accordance with the whistleblowing-related personal data processing notice;
a defined timeline for the handling of reports, providing for:
 communication to the Reporting Person of the timeframe for the admissibility assessment within two (2) working days of receipt of the report;
completion of the investigation phase within a period not exceeding two (2) months.
 
 
External reporting channel (ANAC)
The Company informs Reporting Persons that they may also submit reports through the external reporting channel established by the Italian National Anti-Corruption Authority (ANAC)
(https://www.anticorruzione.it/-/whistleblowing), exclusively where:
(a) an internal report has already been submitted and no follow-up has been provided within the prescribed time limits;
(b) the Reporting Person has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest; or
(c) in the other cases expressly provided for under the Whistleblowing Decree.
 
 
Privacy Notices
The Company has adopted the necessary privacy notices to adequately safeguard the confidentiality rights of Reporting Persons, as well as of the persons concerned by the reports, ensuring that the processing of the relevant personal data is carried out in compliance with Regulation (EU) 2016/679 (GDPR) and Legislative Decree No. 196 of 30 June 2003, and in particular in accordance with the principles of necessity and data minimisation.
 
 
5. Final Provisions
The Company reserves the right to amend this Notice, including in light of the specific modalities for the implementation of the GDPR in the individual Member States, any implementing measures adopted by the Italian Data Protection Authority (Garante per la protezione dei dati personali), or any subsequent amendments to the Italian Privacy Code.