Regardless of which communication channel is chosen, we treat all information confidentially. However, we are obliged to observe legal obligations to provide information to authorities as well as legal exceptions to the confidentiality requirement. The confidentiality of the identity of the whistleblower as well as of the other persons named in the complaint is maintained throughout the entire process.
All information is processed by appointed and specially trained employees of the Compliance department They are impartial, independent in the performance of their duties and bound to secrecy. They are also obliged to comply with data protection regulations and to ensure transparency and the rights of all persons concerned
2. How am I protected as a complainant?
Protecting complainants from being discriminated or punished because of complaints or whistleblowing is an important part of our complaints procedure. Intimidation and reprisals against persons who report actual or suspected misconduct in good faith will not be tolerated.
If you feel that you are suffering intimidation or reprisals as a result of your complaint, contact the Compliance Office; such intimidation or reprisals will also be investigated in accordance with the procedures outlined above and further investigated if necessary.
As far as complainants are affected who are employees of a direct supplier, the company shall endeavour to make appropriate contractual arrangements with the supplier.
3. What happens after I submit my complaint?
3.1 Receipt of a complaint
After a complaint is received, its receipt is documented internally and the complainant receives an acknowledgement of receipt within one week.
3.2 Review of a complaint
The Compliance first checks whether sufficient information is available for the examination and investigation of the notified facts.
If this is not the case, the Complaints Office will, if possible, contact the complainant to ask for further information. If neither sufficient information is available nor contact is possible, the case will be closed.
3.3 Investigation of the complaint
The Compliance itself investigates the matter comprehensively or forwards it to the competent department, e.g. within the company, for investigation, while respecting the principle of confidentiality and data protection. If necessary and as far as possible in the case of anonymous complaints, the Compliance or the competent department will discuss the merits of the case with the whistleblower and, if necessary, ask for further information.
If, after clarification of the facts, discussion and investigation, the Compliance or the competent department is convinced that human rights and environmental risks and violations do not exist in its own business area and with suppliers, the case is closed.
3.4 Development of a corrective solution
If, in the opinion of the Compliance or the other responsible department, the investigation confirms human rights and environmental risks or violations in the company’s own business area and at suppliers, a proposal for further corrective action (in particular preventive and remedial measures) is drawn up. As far as possible and reasonable, the whistleblower will be involved in the process.
3.5 Implementation and follow–up
The implementation of the proposed solution is finally followed up by the Compliance or the competent other department.
3.6 Conclusion of the procedure
The whistleblower will be informed of the conclusion of the complaint procedure, if possibility.
The processing time differs on a case-by-case basis and can therefore take from a few days to several months. However, we strive to complete the investigation in a timely manner.
