Whistleblowing procedure
The Whistleblowing procedure regulates the methods of receiving, examining, and resolving reports, the rights and obligations of persons who make reports or publicly disclose information regarding violations of the law, their protection measures, the rights of the persons concerned as well as Romcarbon’s obligations during the procedure.
Situations that are the subject of notification
No employee or collaborator should accept violations of the law by superiors, subordinates, collaborators, or business partners.
Employees and collaborators are requested to take steps to eliminate situations of violation of the law.
Every employee and collaborator are authorized to make reports, including anonymous ones, for observed or suspected violations of the law.
The following situations must be reported:
a. Violations of the law, in the sense of Law no. 361/2022 and of the procedure.
b. facts that consist of an action or inaction that constitute non-compliance with the legal provisions, which concern areas such as:
• public procurement,
• services, products, and financial markets,
• prevention of money laundering and terrorist financing,
• product safety and conformity,
• transport safety,
• environment protection,
• radiological protection and nuclear safety,
• safety of food and animal feed,
• animal health and welfare,
• public health,
• consumer’s protection,
• the protection of private life and personal data
• the security of computer networks and systems,
• violations that affect the financial interests of the European Union, as mentioned in art. 325 of the Treaty on the functioning of the European Union and how they are detailed in the relevant measures of the European Union;
• violations related to the internal market, referred to in art. 26 para. (2) of the Treaty on the Functioning of the European Union, including violations of the European Union rules on competition and state aid, as well as violations related to the internal market in terms of acts that violate the rules on corporate taxation or mechanisms whose purpose is obtaining a fiscal advantage that contravenes the object or purpose of the law applicable to corporate taxation.
Information on attempts to hide these violations is also considered.
The previous list does not represent a limiting enumeration of the situations that can be the subject of reports.
Whistleblowers, including company employees, can report other situations, which in their opinion, formed in good faith, produce or are likely to produce a violation of the law.
Please note that complaints regarding the quality of products supplied by ROMCARBON SA are not subject to this notification mechanism.
Reporting methods/channels
The report can be made by the whistleblower in oral or written form, anonymously or by declaring his identity and signed / assumed, using one of the following methods:
1. By reporting within ROMCARBON S.A.:
To the Integrity Officer in person or by e-mail at the following address: rapportari.integritate@
By sending a letter to / for the attention of the Integrity Officer at the following address: Romcarbon SA, Strada Transilvaniei no 132, Buzău, Integrity Office.
Through the external communication channel that guarantees anonymity and confidentiality: accessing the reporting form at https://whistleblowing.
2. By reporting outside ROMCARBON S.A., if none of the internal reporting channels is accessible/functional, to the authorities and public institutions that, according to the special legal provisions, receive and resolve reports related to violations of the law, in their field of competence, to the National Integrity Agency and/or to other authorities and public institutions to which the Agency forwards the reports for competent resolution.
For clarity and for the efficiency of the procedure, the report must contain sufficient information, able to answer at least the following questions:
Where? – the name of the company to which the report refers. If possible, additional locations related to the reported suspicion or reported law violation will be provided.
Who? – any data/information known to the person making the report, which identifies the person subject to the report or which is related to the report. The information regarding the facilitator/facilitators or other persons who could support/confirm what was reported, who witnessed the facts that are the subject of the report or who are/may become injured/affected persons by the reported situation/violation.
What?– A description of the event/violation of the law with all the information, documents, or records on which the report is based, if they are related to the violation of the law produced/to be produced.
When? – the date of the event and / or the period in which the violation of the law took place or any other relevant calendar data that can facilitate the most precise time placement of the moment when the act/deed took place/is about to take place.
How? – By what means, tools or systems was the violation of the law committed
Why?– Why, in the whistleblower’s conviction, did the concerned person commit the violation of the law and if, respectively, why is the whistleblower and/or the Company and/or the person injured by the violation of the law considered prejudiced.