]]>
Skip to main content

COMPLIANCE

Trust and respect for customers, partners and employees have always been present among the core values of the Zschimmer & Schwarz Group. Our compliance management system is based on the highest standards and is continuously being improved. We aim to make compliance an integral part of all business processes as part of our corporate culture.

 

CODE OF CONDUCT FOR SUPPLIERS AND EMPLOYEES

Zschimmer & Schwarz expects its suppliers and employees to act responsibly, comply with applicable laws, and adhere to ethical principles whenever and wherever they are. For this reason, Zschimmer & Schwarz has drafted a code of conduct for suppliers and a code of conduct for its employees that describe the minimum standards that suppliers and employees of Zschimmer & Schwarz must follow.

 

 

VIOLATIONS OF APPLICABLE LAWS AND CODES OF CONDUCT

At Zschimmer & Schwarz, we do not tolerate violations of applicable laws and codes of conduct. If any person, as outlined below, should become aware of a violation to an applicable law or to what is expressed in the codes of conduct, or is concerned about a particular behavior, he or she may report it using the channels put in place.

 

Reporting a Violation

 

At Zschimmer & Schwarz we aspire to be an exemplary company in every aspect. This is why it is our responsibility to ensure compliance with applicable national and international laws and regulations. In order to achieve this goal, it is important to become aware of any misconduct and to remedy it. Our whistleblowing system offers several methods for contacting us and reporting violations.
Zschimmer & Schwarz Italiana, being based in Italy, is subject to Legislative Decree 24/2023, which is why the constraints for whistleblowing reports, referred to it, are as indicated below and will be handled by specially appointed and trained Zschimmer & Schwarz Italiana personnel. Therefore, in the event that the report is not referred to Zschimmer & Schwarz Italiana, the TEAM will notify the whistleblower of the impossibility of processing the report and the need, on the part of the whistleblower, to forward it to the correct recipient, in all cases guaranteeing the confidentiality of the information reported.

 

Who can report a violation?

 

In accordance with Legislative Decree 24/2023, individuals entitled to report violations are those who have an employment relationship with Zschimmer & Schwarz Italiana and are referred to as Whistleblowers. An employment relationship is defined as an employee relationship with Zschimmer & Schwarz Italiana, whether fixed-term or open-ended, paid or unpaid, existing or already concluded. Individuals who are in the selection or pre-contract stage with Zschimmer & Schwarz Italiana may also report violations. In addition, suppliers, customers, contractors, consultants and interns, whether paid or unpaid, and volunteers may report violations.

 

What can be reported?

 

In accordance with Legislative Decree 24/2023, violations of national and international regulations and corporate codes of conduct may be reported. Excluded are:
- objections, claims or requests related to a whistleblower's personal interest that refer exclusively to his or her individual working relationships, or inherent in his or her working relationships with hierarchically subordinate figures.
- Reports of violations where already mandatorily regulated by European Union or national acts indicated in Part II of the Annex to Legislative Decree 24/2023, may be made through the channels indicated below but will be processed in accordance with the relevant applicable regulations.
- Reports of national security breaches, as well as of procurements related to defense or national security aspects, unless such aspects fall under the relevant secondary law of the European Union.
- Reports and inquiries regarding Zschimmer & Schwarz products, such as complaints and requests for warranties. For these reasons you should report to your contact person at the Customer Care Office.

 

Whistleblowers should make reports only if they believe, in good faith, that the reported event is accurate. Reporting is not in good faith if the whistleblower knows that he or she is reporting a fact that is untrue or inaccurate. If the whistleblower has doubts about it, the facts should be reported as assumptions, evaluations, or statements of other people.
It should be remembered that the whistleblower may be liable to prosecution and/or sanctions under labor law if he or she makes false statements about other persons.

 

To whom is the report sent?

 

Ideally: report to your supervisor or trusted contact.
Open communication is the basis of the corporate culture to enable full compliance. Staff must be able to address errors openly and especially early on. The initial contact should therefore always be your supervisor. If, on the other hand, you are a third party, get in touch with your reference at Zschimmer & Schwarz.


An alternative: report to the whistleblowing management team.
If, for any reason, you do not feel you can report to your supervisor or trusted contact, get in touch with the whistleblowing management team, (hereafter "TEAM"), using one of the channels described.

 

  • Internet-based whistleblowing system: report through the whistleblowing computer platform that can be reached by clicking here.
    The whistleblowing IT platform allows for whistleblowing with regard to Zschimmer & Schwarz Italiana S.p.A. It is possible to report anonymously but it is strongly recommended that you enter your own data. Please remember that confidentiality is the basis of the entire system. Upon completion of the report entry, the system provides the whistleblower with a unique code, (which the whistleblower MUST note down), that allows access to the report, at later times, in order to be kept up-to-date on the progress of the investigation. At the same time, the platform automatically sends an acknowledgement of receipt to the TEAM, which will proceed, taking steps to ensure maximum confidentiality, to evaluate the report
  • Telephone system: by contacting +39 0161 1760195 you can, after listening to the recorded message, leave your report. The system disguises the voice of the whistleblower to allow total anonymity. In case the whistleblower does not wish to enjoy anonymity, (while enjoying the confidentiality required by the Decree), and wish to be updated about the report, he/she can leave his/her contact details, in particular e-mail or phone number to which he/she can be reached. In the event the whistleblower does not leave his/her contact details, the report will still be taken into account, but there will not be the possibility of a subsequent update regarding its developments. The message is recorded and stored on the same platform used for written reports. After recording, the platform automatically sends an acknowledgement of receipt to the TEAM, which will proceed, taking measures to ensure maximum confidentiality, to evaluate the report.
  • In-person meeting: the whistleblower may request an in-person meeting with the TEAM to release his/her report. The TEAM staff, during the meeting, records what the whistleblower says in the Internet-based whistleblowing system. Upon completion of the recording, the TEAM prints out a copy of what the whistleblower has stated, has him or her sign it, and attaches it to the report, at the same time it provides the whistleblower with the unique code to follow the update of the investigation through the Internet-based whistleblowing system, or, if the whistleblower wishes, he or she may request periodic in-person meetings. The report, in this case, cannot be anonymous.

     

 

What happens after making a report?

 

We verify each report and treat them with absolute discretion. Within 7 days from the date of the report, (whichever of the 3 available forms adopted by the whistleblower), TEAM confirms, through the Internet-based whistleblowing system, receipt of the report to the whistleblower, and the whistleblower can verify this using the unique code provided when registering the report. If the whistleblower issued the report during an in-person meeting, confirmation of receipt is issued at the end of the meeting.
After acknowledging receipt of the report, TEAM verifies the validity of the report under Legislative Decree 24/2023. If the report is deemed invalid because it concerns the topics excluded by Legislative Decree 24/2023 listed above, or because it is insufficiently substantiated and without the possibility of contacting the whistleblower within the stipulated 3-month period, it is dismissed. If, on the other hand, it is considered valid, it is investigated, even with the help of other colleagues, always maintaining the utmost confidentiality about the reported events and names. If more information is needed in order to proceed with the investigation, the TEAM contacts the whistleblower. If the report was made anonymously through the Internet-based whistleblowing system, questions, to be answered by the whistleblower, are posted on the Internet-based whistleblowing system. If after 3 months there has been no word from the whistleblower, the report is archived.
At 3 months after receipt of the report, TEAM notifies the whistleblower of the results of the investigation. In case the investigation is not finished it communicates the progress and planned activities for its conclusion. In any case upon completion of the investigation, TEAM will inform the whistleblower.

 

Is the process safe?

 

We protect the interests of the whistleblower, those accused, sued or involved in the whistleblowing. Our procedure ensures that information is treated confidentially and that the whistleblower, acting in good faith, is protected, by necessary means, from any adverse effects or retaliation he or she may suffer as a result of the report. However, when investigating a report, we also take into consideration the legitimate interests of the people involved in the report. Suspicions or allegations can have significant consequences for the people accused. For this reason, we encourage you to use the whistleblowing system responsibly.