Whistleblowing Platform

SEA values respect for the ethical principles that the Company has adopted, as well as respect for national and extra-national laws and regulations, as fundamental.  In this context, the Company has developed a reporting management system (so-called “Whistleblowing”) that provides for the use of an IT platform, the technical management of which is entrusted to a primary operator in the sector, through which employees, collaborators, consultants, suppliers of SEA and any other third party that entertains a relationship with the Company can submit reports.

The platform guarantees the confidentiality of the reporting subject’s (hereinafter also referred to as the “whistleblower”) personal data, if entered in the system, and of the content of the reports. The platform is located at a site outside SEA and access thereto is not traced.

How to access the platform

The platform for sending reports is accessible at the following link: Whistleblowing SEA
The platform issues a code to the whistleblower  - code that is no longer traceable once the report has been submitted and which is to be kept by the whistleblower - that allows him/her to subsequently re-enter the application and monitor the report’s progress status, as well as communicate to the competent body any further information or attach useful documents to ascertain the facts reported.

What to report and whom to address the report to

Reports may be sent to one of the following competent bodies - which on the platform correspond to different channels - depending on the content of the report itself:

  • Ethics Committee:

For reports relating to conduct that is in violation of the Code of Conduct (e.g. alleged corruption, conflicts of interest, lack of protection or improper use of corporate assets). For complete case studies, please refer to the SEA Code of Conduct at the following link.

  • Supervisory Board:

For reports relating to the alleged commission of crimes referred to in Legislative Decree No. 231/2001 (e.g. environmental crimes, violations of occupational health and safety regulations, crimes against the State or another public body, etc.) or for failure to comply with corporate procedures. For the complete list of offences envisaged by Legislative Decree No. 231/2001, see the SEA Organization and Management Model - General Section, at the following link.

The competent bodies listed above (Ethics Committee and Supervisory Board) rely on the Auditing Department to investigate the reports received.

  • Auditing

For reports relating, for example, to procedural violations, fraud, non-compliance with contractual clauses, as well as reports that do not fall within the sphere of competence of the above-mentioned bodies;

  • Chairman of the Control, Risk and Sustainability Committee

To be addressed only if the report concerns the Auditing Department of SEA or the Auditing Department has a potential interest vested in the report such as to compromise its impartiality and independence of judgement.

For commercial or operational communications (e.g. complaints, requests for commercial information...), the communication channels already adopted by SEA on the site remain valid.

Confidentiality regarding the identity of the reporting subject and content of reports

Reports are handled confidentially by the competent bodies and the identity of the reporter, if declared, is not disclosed, except in the cases provided for by law. 
During the report’s internal verification process, all the rights of the reported person are guaranteed and in no case is a procedure initiated in the absence of tangible evidence regarding the allegations made in the report itself.

The whistleblower may not be subject to discriminatory measures directly or indirectly resulting from the report, either during the process of managing the report or afterwards. 
In particular, if the whistleblower is an employee of the Company, except in cases of liability for willful misconduct or gross negligence, or by way of slander or defamation, or also in cases of whistleblowing with ill intent, the application of any discriminatory, disciplinary and/or retaliatory management measure, direct or indirect, for reasons directly or indirectly related to the whistleblower, is expressly prohibited.

SEA expressly reserves the right to take any action to protect its interests, whether direct or indirect, in the event of reports made with ill intent or that are defamatory or slanderous, which may damage or otherwise cause prejudice to its employees, the members of its corporate bodies or third parties that entertain business relations with the Company. SEA’s disciplinary system establishes a set of sanctions for those who intentionally or gross negligently submit reports that prove to be unfounded.

To access the platform, click here:
Whistleblowing SEA