We attach great importance to the observance of rules and laws, which is why compliance with both legal and internal regulations, i.e. so-called Compliance, is one of the missions systematically pursued within our company. At the same time, we are well aware that even the best Compliance Management system cannot prevent isolated breaches. But this does not mean that we accept them. On the contrary, we want to clarify them as far as possible, remedy them and learn from them for the future. Because only in this way can we improve our Compliance Management and limit the likelihood of further Compliance breaches in the future.
That's why we support the reporting of compliance violations. Many whistleblowers, however, fear reprisals if they draw attention to abuses. For this reason, we have commissioned the accounting firm Grant Thornton AG to collect such information and warnings confidentially. Furthermore, it is forbidden to punish information given in good faith in any way whatsoever. Informers and whistleblowers acting in good faith must not be penalized or exposed to reprisals under any circumstances.
On the following page, you can join Grant Thornton's online reporting and alert system.
Alert and warning systemThis system offers whistleblowers the opportunity to report breaches of Compliance on a confidential and, if they wish, anonymous basis. In order to be able to verify this information as quickly as possible, it is useful for the inappropriate behavior or misconduct underlying the case to be described as precisely as possible. For this reason, the reporting and alert system offers the option of asking questions to provide the best possible assistance in providing the necessary information. At the same time, despite the guarantee of anonymity for the informant or whistleblower, the whistleblower and Grant Thornton are able to communicate, for example, to shed light on questions that remain unanswered. In addition, each whistleblower will be kept regularly informed - to the extent that information processing permits - of progress in clarifying the case he or she has reported.
Moreover, whistleblowers and informants also have the opportunity, via the whistleblowing and reporting system, to contact Grant Thornton for a personal interview.
Misuse of the reporting and alert system will not be tolerated. Please note that deliberately making false allegations about third parties may constitute a criminal offence.
We are obliged to respect the protection of personal data; this also implies that we guarantee all the rights of the persons concerned, including therefore the rights of the person against whom the informant or whistleblower makes the accusation of a breach of compliance. This also includes the right of access to all the personal data of the data subject processed in connection with the information or alert. In general, the data subject's interest in obtaining access to such data is secondary until the investigation into the alert received has been completed. Once the investigation has been completed, however, the request for information should generally be acted upon. We therefore recommend that all whistleblowers and informants take this into account when making their inquiries, particularly if they wish to remain anonymous.
Further information on this subject can be found on our website, in the Personal Data Protection Statement.
Finally, we would like to point out that Grant Thornton is bound to secrecy with regard to information collected via the whistleblowing system or in any other way; however, such information is not generally exempt from the possibility of seizure, i.e. investigating authorities or other administrative authorities may, on the basis of a corresponding judicial decision, seize such information and thus have access to it.
Independently of the whistle-blowing system, our employees can always contact the Compliance Officer or their line manager at any time.