Violations may consist of unlawful conduct relevant under Legislative Decree 231/2001, the 231 Model, the Code of Ethics, internal regulations, European regulations as indicated in Legislative Decree No. 24/2023, as well as misconduct.
Whistleblowers must report facts they have become aware of within their relationship with ICAM.
ICAM ensures the confidentiality of the whistleblower’s identity and guarantees protection against any retaliatory actions or discriminatory behavior due to the report. It is recommended to review the “Whistleblowing Report Management Procedure” and the “Grievance Report Management Procedure”, as well as the “Privacy Notices regarding data processing”.
Whistleblowing | Crimes and Procedure Violations – Grievance | Misconduct
Anyone who holds functions of representation, administration, or management, or who exercises, even de facto, the management and control of business activities, all employees regardless of their contractual status, those who cooperate and collaborate with ICAM S.p.A. – in any capacity – in pursuing its objectives, and more generally, anyone who has ties with the company due to various legal relationships (e.g., suppliers, consultants, collaborators, partners, candidates, former employees, representatives of local communities, etc.).
Whistleblowing | Crimes and Procedure Violations – Grievance | Misconduct
The confidentiality of the whistleblower’s identity is always guaranteed. Additionally, the whistleblower is expressly required to consent to the communication of their report to third parties other than the managers in order to investigate the report.
Whistleblowing | Crimes and Procedure Violations
Violations of national or European Union regulations, or internal provisions that they have become aware of. In any case, any report transmitted through the reporting channels of this policy will be considered within the limits of its relevance and verifiability.
Grievance | Misconduct
Misconduct in the sphere of Corporate Social Responsibility (CSR): violations of human rights, inadequate working conditions, child labor, gender equity, all forms of discrimination and harassment, rights of local communities, environmental impacts, violations of company procedures that are contrary to the law, internal company procedures, or ethical principles.
Whistleblowing | Crimes and Procedure Violations
By accessing the platform you can make:
Grievance | Misconduct
By accessing the platform and selecting the “Grievance” button, you can make:,
Alternatively, without accessing the platform, via the dedicated email address: grievance@icamcioccolato.it
Whistleblowing | Crimes and Procedure Violations
The Management Committee of the internal reporting channels is composed as follows:
Grievance | Misconduct
The Reporting Management Committee is a multidisciplinary group capable of handling reports with fairness, transparency, and expertise. It is composed of three figures:
