Segregated management of reports, investigation and regulatory flow
Directive (EU) 2019/1937
The KRC® Whistleblowing module, simple and easy to use, is developed in compliance with the regulations (European Directive 2019/1937, Law 179/2017, ANAC Guidelines) and adopting the maximum security measures required by the Privacy Guarantor allowing the confidentiality and anonymity of the Reporting party, of the data and documents at each stage of the flow.
The Whistleblower has an independent form in which, through a guided path, free text fields and the possibility of attaching documents, he fills in the report providing the information to the proposed and selected channels.
The Reporting Party, duly informed about the subjects chosen by the company for the analysis phases, can activate a pre-assessment phase which can be followed by the actual investigation phase carried out by the direct channel or by the alternative channel.
Once the phase of filling in the form with the information deemed necessary is completed, the Reporting party proceeds to send the report, an action that enables the automatisms for maximum security and confidentiality of each relevant element and component - generation of a unique code to be used for subsequent actions of the Reporting party.
The Whistleblower can also decide to enter the description of the report by means of an 'on-the-fly' recording of an audio message which is acquired directly from the platform, becoming an integral part of the report itself.
Interaction with the responsible of the report appointed by the company (channel)
Through the unique key in his possession, the Whistleblower accesses his report, verifying its progress with respect to the actions implemented by the selected channel. Among these, some interventions may be required from the Reporting party useful for integrating information or elements considered relevant for the completion of the investigation.
1. Context Definition
It allows the company configuration and the reference context for an effective, correct and profiled operation of the Whistleblowing module. In particular, the status of the report, the channels to which it can be sent, the set of notifications and any other field presented in the form of the Reporter are configured.
2. Preliminarily Evaluation
If envisaged and selected by the Whistleblower, it allows the subject or the dedicated function to proceed with the decoding and reading of the report, preliminarily evaluating whether to continue with the investigation process or close the Report.
3. Analysis and investigation
It allows the person or function dedicated and selected by the Whistleblower (direct or alternative channel) to monitor the status of the Whistleblowing which is presented in a summary statement as an encrypted code. The Head of the report proceeds with the opening, decoding and reading of the same and starts the investigation phase in which he can request additional contributions from the Reporter, can involve other Investigators or complete the analysis by closing the investigation itself.
Each action is tracked and, thanks to the notification system to (and from) the unique code, the Reporting Manager can interact with the Reporter's form in total security and confidentiality.
Thanks our consultancy partner P4i, the customer can take advantage of additional services:
- Project activities: one-off activities carried out with the aim of defining a governance model in the Whistleblowing area for the Organization or the Group. They are divided into 4 types:
- Preliminary Assessment and Gap Analysis AS-IS process for managing Whistleblowing reports
- Design activities of the Governance Model in the Whistleblowing area, including the drafting of all related legal and procedural documentation (including documentation on the processing of personal data, such as information on the processing and Impact Assessment schemes on the processing of personal data)
- Information, education and on-the-job training activities aimed at personnel, also in relation to the KRC Platform
- In the case of international Groups, extension of the governance Model to the Group companies, through an assessment of the compatibility of the Model with respect to local legislation (European or international) and possible adaptation to different or additional requirements. This assessment is carried out by P4i with the support of its network of law firms covering over 25 EU and non-EU countries
- Ongoing and operational support activities: provision of a multidisciplinary team for support in the complaints management process which includes:
- Monitoring of reports received through the management platform
- The analysis of requests and related regulatory, organizational and technological profiles
- The internal management of requests and the involvement of the different stakeholders
- Support in the preparation of feedback to reporting subjects
- Support in the management of consequent actions and follow-ups