Illicit conduct reporting


    INSTRUCTIONS FOR COMPLETION:

    1) Fields marked with * are not mandatory, in order to guarantee the anonymity of the report.

    2) The subject of the report must be “specific, relevant under the decree on administrative liability of entities, and based on precise and consistent factual elements”, and must relate to: “unlawful conduct of which the reporter became aware in the course of their employment relationship”.

    3) If you wish to make an oral report, you may call the law office of Attorney Pautrier, asking to speak personally with the lawyer, as this concerns a report of unlawful conduct pursuant to Legislative Decree 231 of 2001.

    *Optional fields if you wish to remain anonymous.

    If the report has already been submitted to other internal parties/bodies, please fill in the following fields:

    Description of the report:
    Please specify the period/date and place where the incident occurred, the person who committed the act, any other parties (internal and external to Martin Bauer Spa) involved, how you became aware of the incident, and any other individuals who may provide information about it.

    This report may be submitted anonymously or with your personal details.
    In this regard, and pursuant to Legislative Decree 196/2003, we inform you that any personal data provided by the reporter will be collected and used exclusively by the Supervisory Body (OdV) of Martin Bauer Spa, which acts in a manner that guarantees the confidentiality of the reporter’s identity.
    The investigations conducted by the OdV are aimed at preventing the offences set out in Law 190/2012, in accordance with the rules defined in the Code of Ethics published on this website, to which reference is made for further information.
    The processing of reports will take place through the use of IT tools, in compliance with the provisions of Article 11 of the Code and by adopting appropriate security measures. The person subject to the report will in any case be granted the right of access to relevant data and information — excluding the name of the reporter — for the purposes of defence in any disciplinary proceedings brought against them.
    Please note that reporting violations of the Code of Conduct and the Anti-Corruption Plan, as well as any conduct attributable to episodes of maladministration, constitutes a specific obligation for all recipients (internal and external). A knowing failure to act is sanctioned by the Company if it results in a violation of the Code of Conduct, as provided for by the internal disciplinary system or by contracts in the case of external parties. Similarly, any recipients who intentionally provide false, misleading, offensive or clearly bad-faith information will also be sanctioned. Conversely, the expression in good faith of a legal or ethical doubt on any matter will never be subject to any penalising action (retaliation, hardship or discrimination of any kind). In the event of retaliation, its perpetrators will be subject to disciplinary sanctions. Finally, pursuant to applicable regulations, reports made do not constitute a breach of confidentiality obligations, professional secrecy, or any restrictions on the disclosure of information imposed by contract or by legislative, regulatory or administrative provisions, and, if made for the purposes set out herein and in good faith, do not entail any liability whatsoever. We thank you in advance for the contribution you will make with your report.

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