Pietro Rosa TBM is sensitive to the necessity of ensuring a fair and transparent conduct of its business activities.

Code of ethics

Pietro Rosa TBM is sensitive to the necessity of ensuring, through the implementation of its Code of Ethics, a fair and transparent conduct of its business activities to protect the company’s position and reputation and to guarantee the respect of the work, health and safety of its employees.

The Code of Ethics adopted by Pietro Rosa TBM defines therefore the values to which all those in any relationship with must adhere to, by accepting responsibilities, roles and rules.

The Pietro Rosa TBM Code of Ethics also aims to prevent any situation that might present a conflict of interest for its directors, employees and personnel in dealing with any third parties and as such shall be distributed to the attention of any business partners who is required to know and abide by its rules.

Whistleblowing

In compliance with applicable Whistleblowing legislation and in line with the commitment taken by Pietro Rosa TBM to contrast unlawful conduct, the Whistleblowing Guidelines provide the channels, procedures and conditions for filing Whistleblowing external reports.
Pietro Rosa TBM encourages anyone who becomes aware of violations (behaviours, acts or omissions) of laws or internal company protocols that are, even potentially, detrimental to the integrity of Pietro Rosa TBM, to file a whistleblowing report through the Whistleblowing Platform.
The Whistleblowing Platform is a dedicated IT tool that uses an encryption system to ensure the confidentiality of the identity of the whistleblower, the person concerned, the person mentioned in the report, as well as the content of the report and of the relevant documentation, allowing the competent office to communicate with the whistleblower by providing an acknowledgement of receipt of the report and feedback on the action taken or intended to be taken.
Whistleblowing reports can be submitted in written form via the Whistleblowing Platform or in oral form via phone call. For the latter, the whistleblower may be required to attend a face-to-face meeting with the competent office.
In order to allow a better investigation of a whistleblowing report, the whistleblower should provide, in good faith, all useful information, including, where available, supporting documentary evidence.
Whistleblowing reports may include, but are not limited to, the following topics:

• administrative, accounting, civil and/or criminal offences;
• unlawful conduct relevant under Italian Legislative Decree 231/01;
• breaches of Pietro Rosa TBM Code of Ethics;
• offences falling within the scope of EU or national acts;
• acts or omissions affecting the financial interests of the European Union;
• acts or omissions relating to the internal market.

Pietro Rosa TBM ensures protection against any act of retaliation against the whistleblower for reasons related, directly or indirectly, to his/her whistleblowing report made in good faith. In any case, in order to protect the dignity, honour and reputation of everyone, Leonardo also undertakes to offer maximum protection against defamatory reports.

For more information on the procedures and conditions for filing a whistleblowing report, please consult the Whistleblowing Guidelines.