Strict obedience to the law is very important to us. Therefore, we systematically deal with the compliance of all statutory and internal regulations. However, we are aware of the fact that by using even the best compliance management system individual infringements cannot be ruled out which does not mean that we accept them. On the contrary, we want to clarify, stop and learn from them for the future as this is the only way of improving our compliance management system and reducing non-compliance issues.
Giving clues as to such non-compliance issues is supported. However, whistleblowers fear reprisals. We, therefore, engaged Grant Thornton AG Wirtschaftsprüfungsgesellschaft to receive such clues on a confidentiality basis, It is not allowed to sanction information provided in good faith. Whistleblowers acting in good faith must not be put at a disadvantage or exposed to any reprisals.
The following link provides access to the online-based whistleblower system of Grant Thornton:
This system makes it possible for whistleblowers to confidentially (or anonymously, if desired) report non-compliance issues. In order to pursue leads as quickly as possible underlying non-compliance issues should be described as precisely as possible. By asking specific questions the whistleblower system provides support in furnishing the required information. The system guaranteeing anonymousness also allows for a communication between a whistleblower and Grant Thornton in order to clarify certain details. Depending on the information processed a whistleblower will be informed about any progress made in clarifying the issues reported.
A whistleblower may also use the whistleblower system to contact Grant Thornton in order to personally discuss these issues.
We are committed to data protection which means that data subject rights (including the rights of the person charged with non-compliance by a whistleblower) are safeguarded. This also includes the right to obtain information about the processing of a data subject’s personal data related to a clue. A data subject’s interest in obtaining such information generally takes sec-ond place during investigations. Upon completion of the investigations such request for infor-mation shall be complied with. Whistleblowers are recommended to take this aspect into ac-count particularly if they want to stay anonymous.
For further data protection information see the privacy statement on this website.
It is pointed out that Grant Thornton is under an obligation of secrecy concerning the information provided by a whistleblower; however, such information are not generally exempt from seizure, i.e. based on a corresponding court order investigating authorities or other authorities may seize such information thus having access thereto.