Compliance – Whistleblower

We have implemented a system for reporting violations.

You have the option of submitting your report via our reporting office. You decide whether and which of your contact details you provide and whether you would like feedback. If you request feedback and provide your contact details, you will receive a confirmation of receipt of your report via your specified communication channel within seven days. Furthermore, you will receive information on how your report has been handled, including any measures taken, within three months. 

Your report will be sent directly to our external ombudsman (datenschutz nord GmbH, Dominik Bleckmann, fully qualified lawyer), who will treat it confidentially and, after an initial examination, forward it to our internal office for further action.

You can submit your reports by:

• In person after making an appointment
• Sending a written report by post
• Telephone
• Email
   

datenschutz nord GmbH
Konsul-Smidt-Str. 88, 28217 Bremen
Telephone: +49 421 6966 32 349
Email adress: compliance@dsn-group.de

You have the opportunity to report violations of the law, abusive behavior, or breaches of due diligence in the supply chain, particularly in the following areas:

• Criminal violations
• Violations of protective standards for life, limb, and health, or employees and their representative bodies, subject to fines
• Public procurement
• Financial services, financial products, and financial markets, as well as the prevention of money laundering and terrorist financing
• Product safety and compliance
• Transport safety
• Environmental protection
• Food safety
• Animal health and public health
• Consumer protection
• Protection of privacy and personal data and security of network and information systems
• Infringements affecting the financial interests of the Union as referred to in Article 325 TFEU and as further defined in relevant Union measures
• Infringements of internal market rules as referred to in Article 26(2) TFEU, including infringements of Union rules on competition and State aid, as well as infringements of internal market rules related to acts that violate corporate tax rules or arrangements designed to obtain a tax advantage contrary to the object or purpose of the applicable corporate tax law.
• Human rights violations (e.g., child labor, forced labor, discrimination)
• Labor law violations (e.g., unfair wages, unreasonable working conditions, violations of occupational safety and health)
• Environmental violations (e.g., illegal waste disposal, pollution, violations of environmental laws)
• Health and safety hazards (e.g., lack of protective measures for employees or residents)
• Failure to exercise due diligence (e.g., insufficient risk assessment in the supply chain)
• Violations by suppliers (e.g., non-compliance with social and environmental standards)
• Internal corporate failures (e.g., inadequate measures to comply with the LkSG).

This list is not exhaustive. You can also provide information on violations in other areas. The exact scope of application, which is set out below, can be found in Section 2 of the German Act on the Disclosure of Corporate Wrongdoing (GeschGehG).
 

Scope of Application of the Reporting Office in Accordance with Section 2 of the German Act on the Disclosure of Corporate Wrongdoing (§ 2 HinSchG) & Supply Chain Due Diligence Act § 8 Complaints Procedure 

The reporting office is responsible for receiving reports in the following areas:

• Violations that are punishable by law
• Violations that are punishable by a fine, insofar as the violated regulation serves to protect life, limb, or health or to protect the rights of employees or their representative bodies
• Other violations of federal and state laws and directly applicable legal acts of the European Union and the European Atomic Energy Community 
  • To combat money laundering and terrorist financing, including, in particular, the Money Laundering Act and Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EU) No. 1781/2006 (ABI. L 141, 5.6.2015, p. 1), as amended by Regulation (EU) 2019/2175 (ABI. L 334, 27.12.2019, p. 1), as amended.
  • With requirements for product safety and compliance.
  • With requirements for road safety, concerning road infrastructure safety management, safety requirements in road tunnels, and admission to the occupation of road haulage operator or road passenger transport operator (bus and coach company).
  • With requirements to ensure railway safety.
  • With requirements for safety in maritime transport concerning European Union provisions for the recognition of ship inspection and survey organizations, the liability and insurance of the carrier for the carriage of passengers by sea, the approval of marine equipment, the marine safety investigation, the training of seafarers, the registration of persons on board passenger ships in maritime shipping, as well as EU regulations and codes of practice for the safe loading and unloading of bulk carriers.
  • With provisions concerning civil aviation safety to avert risks to operational and technical safety and in the interests of air traffic control.
  • With provisions concerning the safe transportation of dangerous goods by road, rail, and inland waterways.
  • With requirements for environmental protection.
  • With requirements for radiation protection and nuclear safety.
  • To promote the use of energy from renewable sources and energy efficiency.
  • On the safety of food and animal feed, on organic production and the labeling of organic products, on the protection of geographical indications for agricultural products and foodstuffs, including wine, aromatized wine products and spirits, as well as traditional specialties guaranteed, on the placing on the market and use of plant protection products, and on animal health and animal welfare, insofar as they concern the protection of farmed animals, the protection of animals at the time of killing, the keeping of wild animals in zoos, the protection of animals used for scientific purposes, and the transport of animals and related operations.
  • On standards of quality and safety of organs and substances of human origin, medicinal products for human and veterinary use and medical devices, as well as on cross-border patient care.
  • On the manufacture, presentation and sale of tobacco and related products.
  • On consumer rights and consumer protection in relation to business-to-consumer contracts, on consumer protection in the area of payment accounts and financial services, on price indications, and on unfair business-to-consumer commercial practices.
  • On the protection of privacy in electronic communications, on the protection of confidentiality of communications, the protection of personal data in the electronic communications sector, the protection of the privacy of users' terminal equipment and of the information stored in such terminal equipment, the protection against harassment caused by unsolicited calls or calls using automated calling machines, faxes or electronic mail, as well as the presentation and the suppression of calling line identification and the inclusion in directories.
  • The protection of personal data within the scope of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119 of May 4, 2016, p. 1; L 314 of Nov. 22, 2016, p. 72; L 127 of May 23, 2018, p. 2; L 74 of Mar. 4, 2021, p. 35) pursuant to Article 2 thereof.
  • On security in information technology within the meaning of Section 2 (2) of the BSI Act by providers of digital services within the meaning of Section 2 (12) of the BSI Act.
  • On the regulation of the rights of shareholders of stock corporations.
  • On the auditing of the financial statements of public-interest entities in accordance with Section 316a sentence 2 of the German Commercial Code (HGB).
  • On the accounting, including the bookkeeping, of companies that are capital-market-oriented within the meaning of Section 264d of the German Commercial Code (HGB), of credit institutions within the meaning of Section 340 (1) of the German Commercial Code (HGB), of financial services institutions within the meaning of Section 340 (4) sentence 1 of the German Commercial Code (HGB), securities institutions within the meaning of § 340 (4a) sentence 1 of the German Commercial Code, institutions within the meaning of § 340 (5) sentence 1 of the German Commercial Code, insurance companies within the meaning of § 341 (1) of the German Commercial Code and pension funds within the meaning of § 341 (4) sentence 1 of the German Commercial Code.
  • Violations of federal and uniformly applicable regulations for contracting authorities on the procedure for awarding public contracts and concessions and on legal protection in these procedures from the point at which the relevant EU thresholds are reached.
  • Violations covered by Section 4d (1) sentence 1 of the Financial Services Supervision Act, unless otherwise provided in Section 4 (1) sentence 1.
  • Violations of tax laws applicable to corporations and commercial partnerships.
  • Violations in the form of agreements aimed at improperly obtaining a tax advantage that runs counter to the object or purpose of the tax law applicable to corporations and commercial partnerships.
  • Infringements of Articles 101 and 102 of the Treaty on the Functioning of the European Union and infringements of the legal provisions referred to in Section 81(2) nos. 1, 2a and 5 and subsection (3) of the Act against Restraints of Competition.
  • Violations of the provisions of Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828 (Digital Markets Act) (OJ L 265 of 12.10.2022, p. 1).
  • Statements by civil servants that constitute a breach of the duty of allegiance to the constitution.
  • Breaches related to the protection of the financial interests of the Union within the meaning of Article 325 of the Treaty on the Functioning of the European Union.
  • Breaches of internal market rules as referred to in Article 26(2) of the Treaty on the Functioning of the European Union, including European Union rules on competition and state aid, beyond what is referred to in paragraph 1, point 8.
• Breaches in the supply chain
• Human rights and environmental risks