Reporting in accordance with Law no. 361/2022 on the protection of whistleblowers in the public interest

Serafino JWL S.R.L. ensures the confidentiality of the identity of whistleblowers in the public interest and handles all reports of potential legal violations with due care and responsibility.

General information

Individuals who wish to report breaches of the law identified in a professional context (hereinafter referred to as whistleblowers) may submit reports through internal or external reporting channels, in accordance with the provisions of Law no. 361/2022.

Internal reporting channels

Reports may be submitted internally to Serafino JWL S.R.L. using the following channels:

• 
  By telephone, at +40 748788881, Monday to Friday, between 09:00 – 17:00;
  In writing, by completing the reporting form and submitting it:
  by e-mail to contact@serafinojewellery.com or
  by post to the company’s headquarters:
  Calea Floreasca 144, ap.03, District 1, Bucharest
  with the mention “For the attention of the Integrity Whistleblowing Officer”;
  In person, by contacting the designated person at:
  1B, 157 Dorobantilor Way, District 1, Bucharest
  Monday to Friday, between 09:00 – 17:00.
  

External reporting channels

Whistleblowers may also choose to report externally, through the reporting channels operated by the competent authorities, in particular the National Integrity Agency (ANI) or other public bodies legally authorised to receive and handle such reports, depending on the field concerned:

• 
  Online, via the Whistleblowers Platform:
  https://avertizori.integritate.eu/
  
• 
  By e-mail, at:
  avertizari@integritate.eu
  
• 
  By telephone, at +40 372 069 869, following the steps:
  1 – Romanian language selection,
  0 – consent to call recording,
  3 – Public Interest Whistleblowers Directorate;
  (calls are automatically recorded)
  
• 
  By post, to:
  National Integrity Agency,
  15 Lascăr Catargiu Boulevard, Postal Code 010661,
  District 1, Bucharest – Romania,
  For the attention of the Public Interest Whistleblowers Directorate;
  
• 
  In person, at the headquarters of the National Integrity Agency, subject to prior appointment requested via e-mail at avertizari@integritate.eu.
  

Legal framework

This procedure is governed by:

Law no. 361/2022 on the protection of whistleblowers in the public interest

Frequently Asked Questions

A. What is meant by “breaches of the law”?

Breaches of the law refer to acts or omissions that constitute violations of legal provisions set out in Annex no. 2 to Law no. 361/2022, covering areas such as:

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  public procurement;
  
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  financial services, products and markets, prevention of money laundering and terrorist financing;
  
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  product safety and compliance;
  
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  transport safety;
  
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  environmental protection;
  
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  radiation protection and nuclear safety;
  
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  food and feed safety, animal health and welfare;
  
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  public health;
  
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  consumer protection;
  
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  protection of privacy and personal data, and security of network and information systems.
  

They also include:

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  violations affecting the financial interests of the European Union;
  
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  breaches related to the internal market of the EU, including competition and state aid rules, as well as corporate taxation rules;
  
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  actions constituting disciplinary offences, misdemeanours or criminal offences, or actions contrary to the purpose or spirit of the law.
  

B. What happens in the case of false reporting?

Knowingly reporting false information constitutes an administrative offence and is punishable by a fine ranging from RON 2,500 to RON 30,000, unless the act qualifies as a criminal offence under the law.

C. Who may submit a report?

Reports may be submitted by persons who obtained information regarding breaches of the law in a professional context, including but not limited to:

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  employees of the company, regardless of the type of employment contract;
  
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  temporary, seconded or delegated workers;
  
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  self-employed persons;
  
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  shareholders, members of management, administrative or supervisory bodies;
  
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  volunteers and trainees, whether paid or unpaid;
  
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  contractors, subcontractors and suppliers;
  
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  individuals involved in recruitment processes or whose employment relationship has ended;
  
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  individuals submitting anonymous reports.
  

D. Anonymous vs. identified reporting

Key differences include:

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  anonymous reports cannot be supplemented through subsequent communication;
  
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  anonymous whistleblowers do not benefit from the protection measures provided by Law no. 361/2022;
  
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  anonymous whistleblowers cannot be informed about the progress or outcome of the report.
  

E. Conditions for protection

To benefit from protection measures, a whistleblower must:

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  fall within one of the categories provided by law;
  
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  have reasonable grounds to believe that the reported information was true at the time of reporting;
  
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  have submitted an internal or external report, or made a public disclosure.
  

Protection also extends to facilitators, related third parties, legal entities connected to the whistleblower, as well as whistleblowers who initially reported anonymously and were later identified.

F. What must a report contain?

A report should include, at minimum:

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  the whistleblower’s name and contact details;
  
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  the professional context in which the information was obtained;
  
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  the name of the person concerned, if known;
  
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  a description of the alleged breach;
  
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  supporting evidence or documents, where available;
  
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  any additional relevant information;
  
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  date and signature.
  

Anonymous reports may be examined if they contain credible indications of a breach of the law.

G. Reporting procedure and follow-up

The whistleblower will be informed of the registration of the report within 7 days.
Feedback regarding the outcome will be provided within 3 months, or 6 months in duly justified cases.
Following the completion of the assessment, the conclusions and any measures taken will be communicated within 5 days.

H. What are follow-up actions?

Follow-up actions include any measures taken to assess the accuracy of the report, address the reported breach and, where appropriate, prevent further violations.