WHISTLEBLOWING

WHISTLEBLOWING

Pursuant to European Directive 2019/1937 and Legislative Decree 24/2023, in order to prevent and deter violations of the public interest, the internal market, the environment, health, animal protection and welfare regulations, as well as environmental crimes and unlawful activities, Atos has established channels and procedures for the internal reporting of unlawful conduct (so-called whistleblowing), with a view to further strengthening the fairness and transparency of its business activities.

Who can report
The procedure is dedicated to all those who are connected to Atos by virtue of an employment or self-employment contract, its shareholders, members of the administrative, management or supervisory body, and anyone employed under the supervision and direction of contractors, subcontractors and suppliers of Atos.

What should be reported

The object of the report may be a conduct that the reporting individual may consider against:

  1. national or European Union regulations,
  2. the Code of Ethics adopted by Atos,
  3. more generally, the provisions and principles relating to the protection of fundamental freedoms and human rights, the environment, public health, consumer protection, product safety and conformity, and privacy.

The Whistleblowing channels set up by Atos S.p.a. are not intended for reports of personal interests for the reporting individual, pertaining to their individual working situation or regarding professional relations with their superiors (e.g. labour disputes, discrimination, interpersonal conflicts between colleagues, reports on data processing carried out in the context of the individual working relationship, in the absence of damage to the public interest or to the integrity of the private body or public administration).

How to report
Atos has designed and put in place the following reporting channels, which will be securely managed by the Appointed Handler in such a way as to ensure the confidentiality of the reporting individual’s identity and the protection of any third parties named in the report.

Reports may be submitted:

  1. by email to whistleblowing@atos.com
  2. by registered letter to: ATOS S.P.A., Via alla Piana 57, 21018 Sesto Calende (VA), c.a. ufficio legale (Legal Department);
  3. by letter deposited into the mailboxes specifically provided by ATOS S.P.A. located at the company's premises;
  4. reports may also be made in person at a meeting with the Appointed Handler, which must be requested by the reporting individual using one of the above methods.

In the case of reports made in the manner set out in (ii) and (iii) above, the reporting individual must place two sealed envelopes inside a larger sealed envelope, one containing the identification details of the reporting individual together with an identification document, and the second the containing subject of the report.
The reports will be handled by an impartial and competent Appointed Handler, capable of following them up, while ensuring the utmost confidentiality with regard to the identity of the reporting individuals, and any other information that may allow them to be identified, directly or indirectly. Access to the reporting channel by unauthorised personnel is prevented and not permitted.
The reporting individual will receive an acknowledgement of receipt from the Appointed Handler within seven days from the date of receipt of the report by the same.
The outcome of the report will be issued within a time frame of no more than three months from the date of receipt of the report.