The whistleblowing system is an integral part of our culture, which is based on transparency and openness. We want to create a work environment where employees feel safe to report issues and where compliance with the law or internal policies is a top priority. We want to make it clear that the use of our whistleblowing system has nothing to do with denunciation, smearing or snitching. We do not want our employees or other stakeholders to withhold information out of fear or caution. Instead, we encourage you to provide us with truthful and relevant information about possible violations of the law or internal policies. This is in the interest of the legality and integrity of our organisation.
Confidentiality: All reports and, above all, the identity of the person making the report are treated confidentially; in principle, only the internal reporting office has access to the reports.
Your privacy and trust are extremely important to us. All reports made through the whistleblower system are treated in strict confidentiality.
Our whistleblower system allows for different types of reports, where the processing of data on the identity of the whistleblower is carried out as explained below, depending on the type of report selected:
Anonymous Report
If an anonymous report is offered, no personal data on the identity of the person submitting the report is collected in the context of submitting an anonymous report. Accordingly, the person making the report cannot be actively contacted by the person responsible, e.g. for a confirmation of receipt or queries, but communication is possible via the report page displayed after the report has been submitted if the person making the report remembers the URL or the QR code of the report page.
Pseudonyms Report
In the case of a pseudonymous report, the information on the identity of the whistleblower is only transmitted to the service provider who provides the whistleblowing system. This service provider is Compliance.One GmbH. The Compliance.One service provider also maintains the confidentiality of the identity of the whistleblower vis-à-vis the responsible party to whom the report is addressed. The responsible party can communicate with the person making the report via the Compliance.One service provider, e.g. to confirm receipt of the report, to ask questions about the reported facts and to provide feedback on follow-up measures. The responsible person to whom the report is addressed does not receive any information about the identity of the person making the report or their contact details. The service provider Compliance.One ensures effective pseudonymisation of the personal data of the person making the report vis-à-vis the person responsible to whom the report is addressed.
Transparent Report
In the case of a transparent report, the internal reporting unit of the responsible person receives the information provided by the whistleblower on his or her identity, including the contact details provided.
Confidentiality obligation of the internal reporting office
When processing the report, there is an obligation to maintain the confidentiality of the identity of the person providing the information. Only the internal reporting officers who are entrusted with the processing of the report have knowledge of the identity of the person providing the information. The internal reporting officers are obliged to maintain strict confidentiality within the scope of their activities.
If the internal reporting office is operated by the external service provider Compliance.One as an outsourced internal reporting office, the external service provider Compliance.One is subject to a strict obligation of confidentiality regarding the identity of the whistleblower, just like the internal reporting office.
Personal Meeting
Our internal reporting office is also available for a face-to-face meeting upon request. A face-to-face meeting to report a potential violation can be requested at any time through our whistleblowing system. The internal reporting office will then contact the whistleblower in a timely manner to arrange a face-to-face meeting. The meeting can also take place as a video conference with the consent of the whistleblower.
Abuse
In the event of misuse of the whistleblowing system, where incorrect information about violations is reported intentionally or through gross negligence, the identity of a whistleblower is not protected.
Transparent processing: All whistleblowers receive feedback on whether and what action has been taken as a result of their report.
After a report has been submitted, the internal reporting office confirms receipt of the report to the person making the report within seven days.
Every report to our whistleblowing system is thoroughly checked by the internal reporting office. If further information is needed, the whistleblower will be contacted.
If this initial check reveals a concrete suspicion of a violation of laws or internal guidelines, an investigation is initiated. Subsequently, the results of the investigation are evaluated and appropriate follow-up measures are initiated.
The whistleblower shall receive feedback on the status of the processing of the report within three months of the acknowledgement of receipt of the report. The feedback includes the notification of planned and already taken follow-up measures as well as the respective reasons. Feedback will not be provided if this would affect internal investigations or the rights of reported persons.
Confirmation of receipt, possible queries and feedback is possible for anonymous reports via the report page if the person making the report remembers the URL or QR code of the report page.
Within the scope of its activities, the internal reporting office is independent, i.e. it decides independently whether, for example, internal investigations are initiated as a result of a report.
All notifications are permanently documented in accordance with legal requirements so that correct processing can always be traced.
Protection from reprisals: Whistleblowers need not fear reprisals for making a report.
Whistleblowers do not have to fear any reprisals, such as a warning, dismissal or other disadvantages, if they make a report. We will take all necessary steps to ensure that a whistleblower's rights and professional status are not affected as a result of making a report.
To ensure effective protection against reprisals, there is a reversal of the burden of proof - that is, in case of doubt, the employer must prove that a measure is not related to a report.
A whistleblower who nevertheless suffered reprisals also has a claim for damages.
Only relevant Reports: We ask whistleblowers to report only relevant facts to the internal reporting office.
Our whistleblowing system or internal reporting office is not a general complaints hotline. We ask that you only report relevant facts to the internal reporting office that actually provide a solid indication of a violation of laws or internal guidelines.
We ask that only relevant information be reported and that no information, in particular no personal data, which is unrelated to the potential breach or not necessary for its clarification and sanctioning be included in the report.
In the event of intentional or grossly negligent reporting of incorrect information, there may also be a claim for damages against the person providing the information.
Free choice between internal and external reporting office: Whistleblowers can choose whether to contact our internal reporting office or an external reporting office.
Whistleblowers have the free choice between reporting to our internal reporting office and the external reporting offices of the authorities.
However, reporting to the internal reporting office should be preferred to give us the opportunity to quickly detect, investigate and stop violations of laws or internal policies. If an internally reported violation is not remedied, the person making the report is free to contact an external reporting office.
An overview of external reporting possibilities can be found here: www.compliance.one/externemeldestellen/
Thank you for being part of our effort to promote a responsible and ethical culture in our organisation.
