Reporting of Unlawful Conduct
Creativa Srl provides those who work and collaborate with the agency with a confidential channel through which they may report unlawful or irregular conduct that has come to their knowledge in the work-related context.
The channel is a voluntary internal organisational tool, adopted by the Company in the belief that an environment in which problems can be raised without fear is a precondition for better work for everyone. The safeguards described on this page are commitments that Creativa Srl undertakes directly towards reporting persons.
Who May Make a Report
The channel may be used by anyone who works or collaborates with the agency:
The possibility to report is also afforded during the stages preceding the establishment of the relationship, during any probationary period and after the relationship has ended, provided that the facts reported were learned in the work-related context.
What May Be Reported
By way of example, the following may be reported:
The channel does not cover complaints and claims relating exclusively to the reporting person’s own individual employment relationship, for which the usual channels of dialogue with the organisation remain available, nor reports lacking a minimum factual basis.
How to Make a Report
Reports may be submitted, either by name or anonymously:
The officer designated to receive and assess reports is Avv. Gianlupo Macolino, an external professional who is not part of the organisation (the “Designated Officer”). The address indicated is reserved exclusively for the Designated Officer and is not accessible to any corporate function of Creativa Srl.
It is helpful for the report to include, as far as possible: a clear description of the facts; the period and place in which they occurred; any persons involved; and any documents or other supporting evidence. Anonymous reports are taken into consideration if they are sufficiently detailed; anonymity may, however, limit the scope for further investigation and precludes any subsequent exchanges with the reporting person.
This is without prejudice to the right to apply directly to the competent authorities, including the judicial authorities. Use of this channel is neither a condition nor a prerequisite for the exercise of that right.
Safeguards and Confidentiality
Creativa Srl guarantees the confidentiality of the identity of the reporting person and of the persons involved or mentioned, as well as of the content of the report. The information obtained is not used beyond what is necessary to follow up the report adequately and is processed exclusively by the Designated Officer and by any expressly authorised persons.
The identity of the reporting person is not disclosed without their express consent, unless knowledge of it is indispensable to enable the person concerned to exercise the right of defence; in such case, the reporting person is informed in advance in writing, with a statement of the reasons.
No form of retaliation, penalisation or discrimination is tolerated against anyone who makes a report in good faith, or against anyone who assists them. Retaliatory conduct, as well as conduct aimed at obstructing a report or breaching confidentiality obligations, constitutes a disciplinary offence.
Handling Times
Documentation
The Internal Procedure for Reporting Unlawful Conduct and Irregularities sets out in detail how the channel operates, how reports are handled and the measures in place to protect reporting persons.
The processing of personal data connected with reports is described in the dedicated privacy notice, which supplements the general Privacy Policy of the website.
Download the internal PDF procedure
Turin, 30 September 2026
