Whistleblowing

In order to facilitate the monitoring activity regarding the effectiveness of the Organization, Management and Control Model adopted by SERMAG SRL pursuant to Legislative Decree 231/01, as well as to investigate the causes or dysfunctions that may have made a crime possible, any information, communication, and documentation—also from third parties—concerning the implementation of the Model must be forwarded to the Supervisory Body (OdV).

Law 179/2017 and subsequent amendments governs the protection of those who report unlawful acts and irregularities they have become aware of in the context of public and private employment, known as “Whistleblowing.”

This law also amended Legislative Decree 231/2001, modifying Article 6 to require the inclusion within Model 231 of specific internal and external channels for reporting violations, while guaranteeing maximum confidentiality regarding the identity of the whistleblower, as well as protection measures and a ban on retaliation.

Reports can be submitted by the following individuals:

– Employees of the company, including those whose employment is governed by Art. 54-bis of Legislative Decree 24 April 2017, No. 50 (occasional workers);

– Self-employed workers carrying out their activities at the company’s premises, facilities, sites, and production plants;

– Employees of contractors, suppliers, or temporary work agencies operating at the company’s premises, facilities, sites, and production plants;

– Freelancers and consultants who operate at or have contractual relationships with the company;

– Persons holding administrative, management, supervisory, control, or representative positions within the company;

– Volunteers and interns.

Reports may be submitted either orally or in writing.

Oral reports are submitted through telephone lines or voice messaging systems, or—upon request of the whistleblower—through a face-to-face meeting with the Supervisory Body, scheduled within 10 days of the request (extendable if necessary).

Written reports can be submitted via regular mail to the company headquarters in Casale Monferrato (Via Corte d’Appello 3), addressed to the Supervisory Body of SERMAG SRL and marked as strictly confidential, or via direct email to: avvocato.caimo@gmail.com.

Reports must be specific and based on precise and consistent facts and, if possible, should include:

– A clear and complete description of the reported facts;

– If known, the time and place in which the reported facts occurred;

– If known, the identity or other elements (such as role or department) to identify the person(s) involved;

– Identification of any other individuals who may provide information about the facts;

– Any documents that could support the report;

– Any additional information that may help verify the facts.

Reports based solely on rumors or personal grievances or demands of the reporter are not protected.

Furthermore, in compliance with Legislative Decree 24/2023, SERMAG SRL has also activated a digital reporting channel via the “My Whistleblowing – Zucchetti” platform, accessible through the link at the bottom of the page.

After registration, users receive login instructions via the provided email address. The whistleblower completes the report form and may attach documents. A unique report code is issued, which allows the user to track the report and add updates. The platform also allows anonymous reporting, although SERMAG SRL encourages whistleblowers to identify themselves to facilitate fact-checking.