Compliance.

Employees have the right to report circumstances that indicate a violation of the law or internal rules and regulations. The external ombudsman’s office receives these reports and provides a legally protected and confidential point of contact outside the company. It informs whistleblowers of their rights and how to proceed. The ombudsman’s office will only pass on whistleblowing reports to its contact within the company with the consent of the whistleblower. Whistleblowers are not identified in this process. The ombudsman’s office can be involved in the process as a person of trust. It is available to whistleblowers as a contact at any time.

The ombudsman’s office is available to employees, suppliers, distributors and customers, among others.

The ombudsman’s office accepts reports of violations of the law and internal rules and regulations. The main aim is to investigate and prevent economic crime, accounting fraud and misappropriation of assets. However, breaches of internal policies or human rights due diligence obligations can also be reported.

Yes, it is up to the whistleblower alone to decide what information they wish to share with the ombudsman’s office and what information they want the ombudsman’s office to share with the company in the second step of the process. Only if the system is misused, i.e. if deliberately false allegations are made, may the ombudsman’s office disclose information against the will of the whistleblower. The ombudsman’s office will inform whistleblowers of this when they first contact the office.

No, anyone can use the ombudsman’s services free of charge.

Yes, whistleblowers can contact the ombudsman’s office anonymously. This applies from the very first contact. If the whistleblower wishes, the ombudsman’s office will subsequently maintain the whistleblower’s anonymity vis-à-vis the company.

Your report will be investigated in accordance with the law and internal rules and regulations, taking into account the interests of all parties involved. The ombudsman’s office will investigate the matter and then refer it to the appropriate contact within the company.

Whistleblowers can contact the ombudsman’s office at any time to request information on the progress of their case. The ombudsman’s office will inform them of the outcome of their case at the latest when the case is closed, to the extent permitted by law.

No, the ombudsman’s office cannot represent a whistleblower in administrative or judicial proceedings. Therefore, the ombudsman’s office cannot and may not take any steps to enforce a whistleblower’s individual rights or claims in court.

Yes, the ombudsman’s office is an independent and autonomous lawyer who does not take instructions from the company on how to handle matters. The ombudsman’s office conducts its own diligent assessment of whether and to what extent it can refer a matter to the company.

Initial contact can be made via the platform (contact link), by phone, email, SMS, post or in a face-to-face meeting.

Yes, every employee still has their line manager, the works council and all existing points of contact as a first point of contact.

Yes, whistleblowers are protected. Any act of retaliation against a whistleblower will not be tolerated.

Although some people remain sceptical, it is actually very rare for false allegations to be reported to an ombudsman’s office. Nevertheless, the ombudsman will inform the whistleblower at the beginning of their conversation that misuse of the whistleblowing system will not be tolerated and that the ombudsman is obliged to pass on the whistleblower’s personal details to the company if the system is misused wilfully, i.e. deliberately. In any event, employees may be subject to disciplinary action if they wilfully misuse the whistleblowing system.

The ombudsman’s office ensures compliance with the statutory data retention obligations and privacy regulations. The personal data collected is limited to information on the identity of the whistleblower and the person(s) concerned.

No. The presumption of innocence applies. Every whistleblower report will be investigated in accordance with the law and internal rules and regulations, taking into account the interests of all parties involved. A decision on any consequences will only be made once the investigation has been completed.

As long as a report is made in good faith, i.e. not deliberately false, whistleblowers are protected from negative consequences.

No, contacting the ombudsman’s office is voluntary. The office has been set up as an additional point of contact.

Yes. The ombudsman’s office is available for confidential face-to-face meetings. Contact the ombudsman’s office to make an appointment.

Yes.

Yes. The ombudsman’s office or the company will inform the whistleblower of the outcome of their case at the latest when the case is closed, to the extent permitted by law.

No. If the ombudsman’s office is required to give evidence in criminal, civil or other proceedings, it will not disclose the name and identity of the whistleblower seeking advice unless it has been expressly authorised to do so by both the company and the whistleblower.

Yes, you can contact the ombudsman’s office in complete confidence to start with. The office informs whistleblowers of their rights at the beginning of the conversation. It is only at the end of the initial discussion that the whistleblower decides whether and in what form the information should be passed on to the company.

The ombudsman’s office will refer the matter to its contacts in the company without identifying the whistleblower. The contact team consists of senior members of the Legal, Human Resources, Group Security and Internal Audit departments.

As a whistleblower, you can also contact the ombudsman’s office if you think you may have committed an offence. The ombudsman’s office can inform whistleblowers of their rights, and voluntary disclosure within an existing employment relationship is viewed positively and may have a mitigating effect in any subsequent judicial proceedings.

No. It is only in narrowly defined exceptional cases concerning really serious crimes that anyone involved must pass on information about the crime to a public prosecutor.

In this case, the ombudsman’s office can contact the company’s executive management directly.

There is no general answer to this question. While some whistleblowing reports can be dealt with in a matter of hours, more extensive investigations may take several weeks.