Adherence to laws, rules and internal guidelines has the highest priority. We protect our company, our employees, customers, and partners only if we act in conformance to the law and with integrity.

The EU Whistleblower directive gives us the opportunity to establish a so-called internal whistle blower system. Our whistle blower system consists of a digital reporting channel, which can be used by our internal and external stakeholders to report information online and by keeping the confidentiality. It can also be used anonymously. The whistle blower system also provides the accessibility via a phone hotline as well as personal meetings with our service provider.

For this purpose, we hired the compliance service provider named Hinweisgeberexperte. Effective imediately, this company is active as the external compliance representative of our company. All stakeholders are asked to report specific evidence about potential violations against current laws and/or misconduct within our company to the external compliance representative by using our new whistle blower system. The compliance representative will handle all tips confidentially and will check each case individually.

The attention and willingness of everybody is required to report specific information about the violation of rules. These can be reported confidentially to the whistle blower system – at any time and in German as well as in English. Reportable rules violations include, for example, violations against our compliance directive or the antitrust law, corruption, violation of human rights, theft, or discrimination.

Report only tips about rules violations

Please contact your direct supervisor if your concern is based on a complaint or if it concerns clients. These issues will not be handled by the external compliance representative.

We also point out that tips should not be reported frivolously. Please understand that intentionally wrong tips are prohibited. Our whistle blower system is used to guarantee our internal compliance and must only be understood in this vein.

Protection for all of those involved

The whistle blower system guarantees the best possible protection for whistle blowers and affected persons. An internal investigation will only be initiated after careful review of the tip and if specific evidence for a rule violation exists. The information will be processed as part of a fair and confidential process. Discriminations, intimidations, or hostilities that are caused by a report to the whistle blower system will be analyzed in the same process and will be avenged accordingly.

Tips reporting – but in a right way!

After receiving the tips, the external compliance representative processes these in accordance with all required processing principles (e.g. confidentiality, protection of the whistle blower). A dialog with the whistle blower is often required to process cases and to possibly initiate the respective investigation measures. It is therefore required that the tip is formulated as specific as possible. It is helpful if a report addresses the following five questions:

• Who? – About whom is this? Who is affected?
• What? – What happened? Description of the issue.
• When? – When did this happen?
• How? – How often did it happen?
• Where? – Where did it happen?

Whistle blowers should ensure that the description can be comprehended also by persons that are not experts of the subject. Therefore, it is helpful if you are available for further questions. The confidential and possibly anonymous communication with the whistle blower expert is possible via the reporting system, because the whistle blowers receive individual access to the whistle blower system, and they can trace how we handle the tips and which follow-up measures were initiated.

In addition to the external compliance representative, other areas in our company may possibly be involved for the processing of tips. For justified tips, our company normally assigns the required internal investigations to investigating functions (such as special checks or security).

Tips reporting – but where?

The compliance service provider named Hinweisgeberexperte is our external compliance representative for the implementation of the EU Whistleblower directive and the whistle blower protective law as well as the central contact point for tips about rules violations.

Please contact Hinweisgeberexperte via one of the channels listed below.

ONLINE FORM

https://whistleblower.cplace.com

PHONE

089 21 52 74 33 (weekdays between 10.00 AM and 5.00 PM)

PERSONAL MEETING

Please set up a date via online form or phone.