FAQ about WHISTLEBLOWING
1. What is whistleblowing?
Whistleblowing refers to an internal company system for reporting misconduct occurring in the workplace context, including administrative offenses, accounting irregularities, civil and criminal violations, or breaches of organizational models.
A whistleblower—someone who, in the course of their work and by virtue of their role or duties, becomes aware of a crime or violation that harms the public interest or the interests of the private company they work for—has both the right and the duty to report it to a designated internal body. This body is responsible for activating appropriate protection mechanisms.
2. Who can make a report?
The reporting channel is available to and can be used by: employees of the company (including interns and volunteers), self-employed individuals, freelancers or consultants, members and shareholders, and anyone working within the company who performs administrative, managerial, supervisory, control, or representative functions.
3. How can I report it?
Reports can be made in written or oral form, but in any case through one of the reporting channels provided by Seppi M. AG (IT-based or analog).
The IT channel is based on a platform accessible via the website: https://www.seppi.com/it/ and can be reached via the website footer or the “Contacts” section.
The analog channel consists of confidential paper communication placed in a sealed envelope in a designated compartment in a restricted company area accessible to internal staff.
The whistleblower may submit a written report or request a direct and confidential meeting with the responsible body within 5 working days.
Reports can also be made externally to ANAC (National Anti-Corruption Authority), but only if:
a) the company has not established an internal reporting channel;
b) a report has already been made but was not followed up;
c) there is reasonable fear that an internal report will not be followed up or that retaliation may occur;
d) the violation represents an immediate or obvious threat to the public interest.
4. How do I use internal reporting channels?
The IT platform is accessible via the company website (https://www.seppi.com/it/) through the footer or “Contacts” section by activating the relevant link.
To submit a report, simply access the platform and follow the guided procedure, completing all mandatory fields.
Important: After submission, the platform generates a secret numerical access code (PIN). This code is strictly personal and must be stored securely by the whistleblower until the procedure is completed. It is required for accessing the report and maintaining communication with the responsible body.
The analog channel consists of confidential paper communication placed in a sealed envelope in a designated company area.
5. Can I recover the access code?
No. For privacy reasons, the code is displayed only once and cannot be regenerated.
It functions as a password and must be securely stored by the reporting person.
6. What can/should I report?
This channel is specifically intended for reporting administrative, accounting, civil, or criminal violations that harm or threaten public interest, the company, the business community, or organizational assets.
It may also be used to report personal issues such as workplace harassment or discomfort, but such reports are not protected under whistleblowing regulations.
Examples:
- An employee resigns via the whistleblowing channel → Not applicable; forwarded to HR.
- An employee reports bullying by a manager → Personal matter but serious; handled by HR with protection measures.
- Complaint about lack of career development → Not applicable (personal evaluation matter).
- Report of suspicious purchases for corrupt purposes → Applicable; protected.
- External worker reports environmental damage → Applicable; must also be reported to authorities.
7. Who manages the reports?
Seppi M. AG has entrusted report management to Susanne Seppi (Head of HR), who handles review, verification, confidentiality, whistleblower protection, and activation of necessary internal or external procedures.
8. What happens after I report?
Within 7 days, you will receive an acknowledgment of receipt.
Within 3 months, you will receive feedback on follow-up actions.
You may be contacted for clarification, so you should regularly check your report file.
9. How is confidentiality protected?
The identity of the whistleblower is protected throughout the process and in any related proceedings.
It may only be disclosed when necessary or with explicit consent.
In disciplinary proceedings, disclosure is limited and strictly regulated, especially if required for the defense of the accused.
10. Can I report anonymously?
Anonymous reports are not protected under whistleblower regulations, though they may still be processed.
11. What if someone makes a false report about me?
False or malicious reports remove protection for the reporting person and may lead to disciplinary action. The accused person will be informed for their protection.
12. How are my personal data processed?
Data are processed in accordance with GDPR (EU Regulation 679/2016).
However, certain rights (access, correction, deletion, etc.) may be limited if exercising them would compromise the whistleblower’s confidentiality.
13. How long is the report stored?
Reports are stored only as long as necessary, then archived (minimized) for 5 years before deletion.
14. Where can I find more information?
Information is available on company notice boards, digital postings, and the company website.
15. Can I still contact my supervisor directly?
Yes. The whistleblowing system does not replace normal internal communication channels. However, it ensures confidentiality and enhanced protection.