What is “Whistleblowing”?

To facilitate the surveillance activity on the efficiency of the Organization and Management Model pursuant to Legislative Decree 231/2001 adopted by SERMAG SRL, and furthermore the assessment of causes/dysfunction that might have made eventually possible the occurrence of the crime. Any information, communication, and documentation, even if it comes from a third party, regarding the actuation of the Model must be forwarded to the Supervisory Order (SO).
Law 179/2017 and s.m.a. (subsequent modifications and additions) regulates the protection of the subject reporting crimes and irregularity, that he became aware of regarding the public and private employment relationship, known as “Whistleblowing”.
The aforementioned law had also intervened on the Legislative Decree. 231/2001, amending article 6 with the obligation to provide within the 231 model, specific channels, internal and external, for reporting crimes, guaranteeing – at the same time – the maximum confidentiality regarding the identity of the whistleblower. Furthermore, the adoption of protective measures for the whistleblower and the prohibition on the adoption of retaliatory measures against the same.

Who can make a report?

The following subjects can make the reports:
– Employees of the company, including workers whose employment relationship is governed by art.54-bis of the Legislative Decree. 24 April 2017, n.50 (casual workers).
– Self-employed who conduct their own activity at the headquarters, the factory, the site, and productive structures of the Company.
– Employees of companies contracting goods and services, suppliers and supply companies who conduct their activities at the headquarters, factory, site, and production facilities of the Company.
– Freelancers and consultants who conduct their activities at the headquarters, factory, site, and production facilities of the Company, or those who, in any case, have contractual relationship with the Company.
– People holding powers and positions in administrative, managerial, of control and supervision, and representation fields within the Company.
– Volunteers and interns.

What can be reported?

The reports can regard, in general, behaviours, acts and omissions that can harm the integrity and the Company’s interests, such as:
– Violation of the national or the European Union regulatory provisions, such as to integrate the possibility of committing the crimes foreseen and regulated within section III, of CHAPTER I, of Legislative Decree 231/2001, if they are applicable to the Company.
– Any violation or non-compliance of norms, rules, protocols, and procedures that are a part of the MOG and the code of ethics adopted by the Company, even in cases where they do not, in themselves, integrate the details of specific types of crime.
Eventual reports of facts and conducts not included in the typologies reported in the previous paragraph will not be treated by the SO with the methods and for the purposes established in the following points, but the SO will transmit the relevant report to the Company, so that the Company can manage them in the ways and forms it deems most appropriate.

How do you make a report?

The reports must be made in oral or written form.
Oral reports are conducted through telephone lines or vocal messaging systems, which is to say, at the request of the reporting person, through a direct meeting with the Supervisory Order, scheduled within the deadline of 10 days from the report, deadline that can be delayed in case of necessity or due to forces majeure.
Written reports can be conducted by ordinary mail to the address of the company headquarters in Casale Monferrato (Via Corte d’Appello, 3), to the attention of SERMAG SRL Supervisory Order, with personal confidential indication or through direct communication with the Supervisory Order at the email address: avvocato.caimo@gmail.com.
The report must be circumstantial and based on precise and consistent factual elements, so it should, if possible, contain the following elements:
– A clear and complete description of the facts concerning the report.
– If known, circumstances of time and place in which the facts concerning the report have taken place.
– If known, the general information or other elements (such as the qualification and the service in which they conduct the activity) that allows to identify the subject/s that has/have implemented the reported facts.
– The indication of any other subjects who can report on the facts covered by the report.
– The indication of any documents that can confirm the validity of these facts.
– Any other information that can provide useful feedback regarding the existence of the facts reported.
Reports based on just suspects or rumours and the personal complaints of the Reporter or claims made by the same are not considered worthy of protection.
Furthermore, in compliance with the new provisions of the Legislative Decree. 24/2023, SERMAG SRL has also activated the reporting method through the IT platform “My Whistleblowing – Zucchetti” accessible through the link at the bottom of the page which will lead directly to the IT platform.
Once you have registered on the IT platform, the user will receive on their given private e-mail address the instruction on how to login. The whistleblower will fill in the reporting form by entering the required information and attaching, eventually, documentation that supports the validity of the facts. Once the report has been made, you will receive a unique personal code relating to the report (Reporting Code) which they will have to use to receive updates on the report made and to add new information. The platform allows the whistleblower who does not want to supply its own personal information (although SERMAG SRL encourages whistleblowers to reveal their identity to facilitate verification of the validity of the complaint) to report anonymously.

Click on the link below to make a report.