Whistleblowing Policy

1. What can be reported

Any reasonable suspicion of a breach of the law, of the Code of Conduct or of a company policy: corruption, sanctions breaches, product defects, data protection breaches, fraud, discrimination.

2. Reporting channel

• Standard route: to Executive Management, in writing or orally.
• If the report concerns Executive Management: directly to the Board of Directors.
• Reports may be made anonymously. Anonymous reports are treated equally, but without the possibility of follow-up questions they can be investigated less thoroughly.

3. Protection of the reporting person

Anyone who reports in good faith must not suffer any disadvantage as a result – neither dismissal nor transfer, disadvantages in performance assessment or exclusion. Their identity is disclosed only to the persons involved in the investigation. Intentionally false reports are not covered by this protection.

4. Procedure

• Confirmation of receipt, insofar as a return channel exists.
• Preliminary assessment of plausibility by the competent body.
• Investigation while preserving confidentiality and the presumption of innocence.
• Measures, documentation and feedback to the reporting person.