Informations about the reporting system
Digital reporting system with the possibility of anonymous reporting
Complying with the law is important to us; which is why we systematically care for the task of adhering to both legal and internal regulations in our company, i.e. with so-called compliance. At the same time, we are aware that even the best compliance management cannot prevent individual breaches of rules. This, however, does not mean that we will accept such violations. Rather, we want to clarify any potential violations as much as possible, put a stop to them and learn from them for the future. This is the only way to improve our compliance management and reduce the likelihood of further compliance violations in the future.
We, therefore, support the submission of information on such compliance violations. Nonetheless, many whistleblowers fear retaliation if they point out wrongdoings. For this reason, we have set up the digital whistleblower system "Whistleblower Software" and decided to commission the external ombudspersons, Christina Odenthal-Middelhoff and Philipp Külz from the law firm Ebner Stolz. The ombudspersons will receive the reports via the "Whistleblower Software" and process them objectively with the necessary professional expertise.
Whistleblowers who, at the time of reporting, had sufficient reason to believe that the information they reported was true, and were therefore acting in good faith, will not be disadvantaged in any way or subjected to reprisals.
Reporting channels for whistleblowers
Simply click on the "To the whistleblower system" button to access our digital whistleblower system. In addition to submitting an anonymous report, it offers the opportunity to report indications of compliance violations in simple steps via the digital portal, stating your identity.
At the same time, the digital whistleblower system then serves as a protected communication channel between the person making the report and the external ombudspersons responsible for receiving the report. Communication is guaranteed via the system even if the whistleblower remains anonymous.
This whistleblowing system does not utilize robots with automated response settings. Rather, each information is received by experienced experts and subjected to an initial check. A decision is then made on any follow-up measures. Our ombudspersons are committed to the objective and fair investigation of allegations of compliance violations.
In addition, every whistleblower is informed – insofar as the processing of the report permits – about the follow-up measures planned and already taken as a result of the report.
Misuse of the whistleblower system
Individuals who improperly or maliciously report inaccurate information are not subject to the protections of the whistleblower system. Therefore, misuse of the whistleblower system will not be tolerated. We point out that deliberately making untrue allegations about third parties may constitute a criminal offence.
Data protection
We are committed to data protection; we therefore handle the data of the whistleblower and third parties mentioned in the report in accordance with the law. This also includes that we ensure all data subject rights, including the rights of the person against whom the whistleblower raises the allegation of a compliance violation. This also includes the right to information about all personal data of the data subject processed in connection with the whistleblowing. As a rule, the interest of the data subject in receiving information about these data will be secondary until the investigation into the received tip-off has been completed. After the investigation has been completed however, the request for information usually must be complied with. We therefore recommend that all persons providing information take this circumstance into account when submitting information, especially if they wish to remain anonymous. For further information on data protection, please refer to the data protection statement on this website.
Further reporting possibilities
Irrespective of the whistleblower system, our employees still have the option of contacting their supervisor or Mr. Michael Schubert with information at any time.