The Fondazione Compagnia di San Paolo (hereinafter referred to as the “Compagnia”), together with its Auxiliary Bodies and the consortium companies PR.I.S.MA and Xké? ZeroTredici, provides an internal reporting channel through which illicit conduct and/or violation of regulations can be reported in a confidential and reserved manner (i.e. whistleblowing).

The internal reporting channel, adopted in accordance with the provisions of Legislative Decree 24/2023 (hereinafter also the “Decree”), allows illicit conduct/violations to be reported through the channel both in written form or orally by a digital platform that can be reached at the following link:


Reports may concern the commission of offenses relevant under Legislative Decree 231/2001 (an updated list of these offenses is attached) and violations of European law as defined by the Decree (an illustrative detail is attached); violations of Model 231 and the Code of Ethics adopted by the Compagnia (both of which can be consulted on its website) may also be reported.

In accordance with the provisions contained in the Decree, reports may be submitted by employees, self-employed workers, collaborators, freelancers, consultants, volunteers, and trainees who work at the Compagnia, as well as by people who hold administrative, management, control, supervisory or representative positions within the Compagnia (i.e. whistleblowers).

The internal reporting channel allows reports to be submitted even in anonymous form, which will be processed only where they are found to be adequately detailed and capable of clearly bringing out facts and situations. Anonymous reports that appear to be groundless or unsubstantiated will not be processed.

Whistleblowers are protected by law against any form of retaliation related directly or indirectly to their reports.

The processing of personal data as part of the process of handling reports is carried out in compliance with the requirements of the Decree and the GDPR.


More information can be found in the “Procedure for handling reports (whistleblowing) according to Legislative Decree 24/2023” provided in an annex, together with the guide for the use of the digital platform.