Whistleblowing

Dear Stakeholder,

American School of Milan, in compliance with the provisions of the law and with a view to guaranteeing correctness and transparency in the conduct of its business, has set up a “Whistleblowing” online system, available to anyone who wants to report situations relevant to the purposes of the law or internal regulations. With the present document, we want to give you the instructions to follow to submit the report. For further information on company procedures regarding reporting offenses, we invite you to consult the specific company rules and regulations.

CHARACTERISTICS OF THE REPORT

The report must refer solely to breaches of the law or of internal procedures and regulations, including the Code of Ethics, therefore, reports concerning complaints, personal requests or, more generally, circumstances not relevant may not be taken into consideration. The reports must be made in good faith, detailed, and based on precise and concordant factual elements, also in order not to waste the effectiveness of the tool made available to you. Anyone who willfully makes reports that subsequently turn out to be unfounded may be subject to disciplinary sanctions.

MANAGEMENT OF THE REPORTS

In order to protect as much as possible the “whistleblower” and the “signaled person”, security measures have been adopted: regardless of the choice made by the “whistleblower” to make an anonymous or nonanonymous report (as indicated in the following point 6), confidentiality of the whistleblower identity and of the content of the report are guaranteed through secure protocols and cryptographic tools that protect personal data and information provided. The identity of the whistleblower is never disclosed without their consent, with the exception of the cases provided for by current legislation. The competent body for the management of reports is the Person in Charge of whistleblowing, who is our HR Manager, Marina Stella. In addition to the information provided, we invite you to read the “whistleblowing” procedure issued by the Company.

HOW TO SUBMIT A REPORT

1. Access the link: https://whistleblowingasm.segnalazioni.eu. Click on the button on the top right to select the language you would like to use to submit your report.

2. Proceed by clicking the ” Make a report” button.

3. Having read the Privacy information, the whistleblower will proceed by filling in the form. The fields marked with the symbol * are mandatory. Some fields are open and must have a maximum number of characters.

4. It will be possible to proceed with the report.

(a) Anonymously ticking the relevant box:

b) or, in a non-anonymous form, but in any case, with the guarantees of confidentiality required by law:

For any further questions or clarifications, please do not hesitate to contact the person in charge for Whistleblowing, Ms. Marina Stella, at the following email address: mstella@asmilan.org