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Whistleblowing Channel

Last updated: August 2026

1. Purpose and scope

DITAP maintains a whistleblowing channel for reporting, in good faith, irregular, illegal, or values-inconsistent conduct within the organization or in the context of our business relationships.

This channel is aligned with the principles of EU Directive 2019/1937 on the protection of persons who report breaches of Union law (the "Whistleblowing Directive"), transposed in Italy through Legislative Decree 24/2023. We apply these same standards voluntarily to our operations in Argentina and Chile, where an equivalent legal obligation doesn't yet exist, because we believe integrity shouldn't depend on jurisdiction.

Matters you can report: breaches of data protection law, fraud or corruption, undeclared conflicts of interest, information security failures, discrimination or harassment, environmental or workplace safety breaches, and any conduct that breaches applicable law or our internal Terms and Conditions (ditap.io/en/terms) of conduct.

2. Who can report

This channel is open to: current employees, former employees (within one year of leaving), job candidates in the selection process, contractors, suppliers, and anyone with an employment or business relationship with DITAP who becomes aware of an irregularity in that context.

3. How to report

The designated channel is [email protected]. In the subject line, write "CONFIDENTIAL — Whistleblowing Channel" so the message is routed directly to the person responsible for handling it, with restricted access.

What to include in your report (everything you can provide helps, but nothing is mandatory):

  • A description of the facts, with dates and locations if known.
  • People involved.
  • Available evidence (documents, screenshots, communications).
  • Whether you'd prefer your identity to stay confidential from third parties (see Section 4).

    • 4. Confidentiality and protection for reporters

    Identity confidentiality: only the person designated to manage the channel knows your identity, unless disclosure is legally required (for example, under a court order) or you've given express consent to reveal it.

    Prohibition on retaliation: DITAP prohibits any form of retaliation against anyone reporting in good faith — dismissal, demotion, discrimination, exclusion, or any unfavorable treatment motivated by the report. A good-faith report is protected even if, after investigation, the reported facts aren't confirmed.

    Bad-faith reports: this protection does not cover reports made knowing them to be false, or with the deliberate intent to harm another person.

    Anonymous reporting: you may choose not to identify yourself. An anonymous report is investigated the same way as an identified one, though the absence of contact details may limit our ability to ask clarifying questions or inform you of the outcome.

    5. Timelines

  • Acknowledgment of receipt: we confirm receipt of your report within 7 days of receiving it (when you left a means of contact).
  • Feedback: we inform you of the outcome or the status of measures taken within a maximum of 3 months from the acknowledgment of receipt (or from the expiry of the 7-day period if no acknowledgment was possible due to lack of contact details).
  • If the investigation requires more time due to its complexity, we'll communicate a revised estimate, when we're able to identify you.

    • 6. Investigation process

    Every report received is reviewed by the person responsible for the channel, who assesses its admissibility, gathers the necessary information, and determines appropriate measures. Where a report involves the person responsible for the channel, review is referred to another person with decision-making authority within the organization to avoid a conflict of interest.

    Access to report data is strictly limited to the people involved in handling it.

    7. External reporting

    If you feel your report wasn't handled appropriately, or you'd prefer to report directly to an external authority, you may turn to:

  • 🇮🇹 Italy: the National Anti-Corruption Authority (ANAC), which operates the external whistleblowing channel under Legislative Decree 24/2023.
  • 🇪🇺 European Union: the competent authority in your country of residence, under the local transposition of EU Directive 2019/1937.
  • 🇦🇷 🇨🇱 Argentina and Chile: the authority relevant to the subject matter reported (for example, data protection, competition, or anti-corruption), since these jurisdictions don't have a whistleblowing authority equivalent to the EU's.

    • 8. Changes to this policy

    We may update this channel as the organization grows — for example, by adding a dedicated tool or formally appointing an internal officer distinct from the general contact channel. Any change will be reflected in the "Last updated" date of this document.