Whistleblowing System

Compliance with legal regulations is always a top priority for our company. We want to ensure that compliance is also guaranteed in the future. Therefore, it is important that violations and misconduct are reported to us. This is the only way we can correct violations and prevent them in the future. To enable the reporting of violations and the issuing of notices, we use a whistleblower system. This system offers our employees, suppliers and other partners or persons related to the company the opportunity to report violations via a secure online platform. Incoming reports are seriously examined and processed accordingly. We guarantee the greatest possible protection for whistleblowers who act in good faith, try to promote correct behaviour and help clarify misconduct. However, tips can also always be submitted anonymously. For the persons accused, the presumption of innocence always applies until the violation can be proven.

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The system

To strengthen trust in the handling of whistleblowing, we rely on transparency. The whistleblower platform we use is the White Sparrow Whistleblowing System. Our system ensures that reports submitted are always in a secure environment and, if desired, processed completely anonymously. This means that in the circumstances of anonymous reports, neither e-mail addresses, telephone numbers nor other identifiers are recorded or stored. The relevant IT systems are ISO 27001/2 certified and the processing of data complies with the provisions of the General Data Protection Regulation (GDPR). All data and messages are transmitted in encrypted form and stored in a database where only persons designated by the company have access to the data. When using the White Sparrow Whistleblowing System, notices can be submitted online all around the clock, seven days a week, worldwide in multiple languages.

Why should I submit a report?

Violations of laws, company policy or codes of conduct harm our company and thus all of its employees. Integrity, respect and responsibility are core values of this company and have an impact not only on sustainable economic success, but also on the well-being of each individual in the team. If misconduct is detected at an early stage, action can be taken against it in good time. In this way, damage to the company and its employees can be averted. Therefore, companies need the help of every individual to avert damage in timely fashion.

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Frequently asked questions

Who can submit a report?

Any employee can report a violation, but interns, freelancers, suppliers, former employees or applicants can also use the whistleblower system. In addition, third parties who have become aware of a violation during a business contact with the company can submit a report.

Is my report really confidential?

We will keep your identity and your report absolutely confidential. The information will be shared only within the company for purpose of investigation. You can choose whether to disclose your identity or remain anonymous. As the information you share with us may lead to investigations and (possibly criminal) consequences for those involved, the information reported must be truthful. False reports and false suspicions can have serious consequences for the whistleblower and may be reported to the police. In this case, you as a whistleblower are not protected by the law. However, you will not face any consequences if you provide your information to the best of your knowledge and belief, even if the information later turns out to be false. Your reasons for the report, on the other hand, are irrelevant as long as they are truthful. Please note that as a whistleblower you may not disclose any information if you are subject to a legally mandated professional duty of confidentiality, such as a medical doctor or tax advisor. In addition, the persons that will examine your report are, under certain circumstances, legally obliged to hand over the reported information to the government or other authorities. This may be the case, for example, if there are legal constraints to involve the authorities in the areas concerned by the information. The company may also be forced to disclose information by investigating authorities (e.g. in the course of a search) or by a court.

How do I submit a report?

In order for a report to be reviewed and processed correctly, it is important that you provide specific information and describe the violation as precisely as possible. At best, you should answer the questions Who? - What? - Where? - How? and When? In order to be able to ensure a thorough clarification, it would be helpful if you were available to answer any questions. It is up to you whether by telephone or by e-mail. Of course, you can also remain anonymous and open an anonymous account after submitting the report (this will be offered to you after submitting the report). This account can then also be used for two-way communication with the company. In addition, you should bear in mind that the report will be reviewed by persons who may not have expertise in your field. Therefore, please try to describe the case as clearly and factually as possible. If you have further questions about the procedure or the White Sparrow whistleblowing system, you can email the White Sparrow team at incident@mkm-compliance.de with your questions. We will be happy to provide you with non-binding and confidential information about the reporting process.

How does the reporting process work?

On the next few pages, you will first be asked to describe the violation to us in as much detail as possible. Please provide us with any information that you believe will be helpful. Information such as your name or position is not mandatory. If you tell us your name and a way to contact you, you will receive a confirmation that your report has been submitted within seven days. Please understand that it may take some time to process your report. We take your report seriously and want to examine it with due diligence. It is possible that we may have queries or require additional information in order to investigate the reported violation. After your report has been submitted, it will be processed and reviewed to determine if further investigation is necessary. Persons who have committed an alleged violation will usually be given the opportunity to comment on it, as they too are worthy of protection until proven guilty. If necessary, the reported incident is passed on to authorities.

What safety standards are met?

The White Sparrow Whistleblowing System is provided by MKM Compliance GmbH as an independent partner. The reports are processed with a software developed out of the finance sector and stored in technically highly secured data centres. The reported information is stored on servers in data centres, which are certified in accordance with DIN ISO 27001/27002, SOC 1, SOC 2 and SOC 3. On these servers, the metadata that is absolutely necessary for transmission, such as IP addresses or network and device specifications, is only stored for an extremely short period of time and then deleted without the customers or employees of MKM Compliance having access to it. A very limited group of administrators of the system developers would have access to this if necessary, but this is prohibited for organisational reasons. In addition, the system is set up in such a way that an IP address cannot be linked to a submitted report. Thus, even access to the data means that an assignment to a report is no longer possible. You decide for yourself whether to remain anonymous or to provide personal details. The contents of your report are transmitted securely and encrypted.

What other reporting channels are there?

A report can be submitted on this platform or via e-mail at incident@mkm-compliance.de. Information received by email is entered manually as a new tip in the whistleblowing system of the company concerned by employees of MKM Compliance GmbH who are sworn to secrecy. If the company concerned enables further options for submitting a report, it may have published this itself.