FAQ

What incidents can be reported through the system?

Report incidents within our company that violate applicable laws or our internal regulations, provided they are related to the company or the employment relationship. Other concerns such as customer complaints, claims, etc., cannot be reported through this channel.

Through this whistleblower system, you can report the following violations:

Violations of EU law. This includes reports on:

• 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,
• radiation protection and nuclear safety,
• food and feed safety, animal health and welfare,
• public health,
• consumer protection,
• protection of privacy and personal data as well as the security of network and information systems (data protection).

Violations of applicable law, provided they are related to the employment relationship. This includes reports on:

• Accepting and granting benefits (bribery and corruption)
• Favoritism towards debtors or creditors
• Corruption
• Counterfeiting of money and securities, forgery of documents
• Acts against sexual self-determination (e.g., distribution of pornographic content through work PCs or the company network, sexual harassment at the workplace)
• Violation of personal privacy and secrecy in or through the employment relationship (e.g., unlawful querying of private data, violation of mail secrecy, breach of confidentiality of speech)
• Acts against physical integrity (e.g., bodily harm)
• Theft and embezzlement in the workplace
• Money laundering
• Fraud and breach of trust
• Forging of data of substantial evidentiary value
• Environmental crimes (e.g., water, air, or soil pollution, unlawful handling of waste, endangerment of protected areas)
• Violations against safety, hygiene, and health protection
• Violations against the protection of working youth
• Violations against the General Act on Equal Treatment (e.g., discrimination and disadvantage based on ethnic origin, religion or beliefs, age, disability, sexual orientation)
• Violations of the Working Time Act

Violations of internal regulations. This includes reports on:

• Violations of internal work instructions
• Violations of internal guidelines or policies
• Violations of ethical principles, commitments, Code of Conduct, or similar standards

Can I submit reports anonymously?

Yes, you can submit reports completely anonymously. We have technically and organizationally secured our whistleblower system in various ways to maintain your anonymity. For instance, we do not store log files (IP address or other data that might reveal your identity) at any time, so we can only identify you if you voluntarily disclose your identity to us. Please consider that anonymous reports often do not provide a solid basis for the clarification of matters. Therefore, we ask you to provide your contact details when submitting a report. The ombudspersons are committed to maintaining confidentiality and safeguarding the privacy of the reporting individual. This is also contractually agreed with your company. Your identity will not be disclosed without your explicit consent.

Who are the ombudspersons?

To avoid conflicts of interest within the company, we have appointed an external person to receive your reports in the whistleblower system. This person is bound by confidentiality and is the only one who will contact you for processing the report. To initiate further actions following a report, the ombudsperson can pass on reports to an impartial entity within our company. Your identity will only be disclosed upon your explicit request. The ombudsperson for our company is:

exkulpa GmbH
Waldfeuchter Str. 266
52525 Heinsberg

We expressly ask that you only contact the ombudsperson through the whistleblower system. Reports outside this system will not be considered.

Will I face consequences if my report turns out to be false?

Generally, at the time of reporting, you should have sufficient reason to believe that the matters you report are true based on the circumstances and available information. Even if you provide inaccurate information about violations in good faith that later turn out to be false, you will not face any consequences. Similarly, you are not required to gather evidence for the reports you submit; we will investigate the violation for you. If there are questions about the incident, we may contact you again through the mailbox.

Intentionally malicious or abusive reports, however, will be pursued by us. If at the time of the report you knowingly and willfully reported false or misleading information, you will not be covered under the protection of the applicable EU directive.

What happens after a report is submitted?

Once you have submitted a report in our system, it will be received by the ombudsperson. Within a maximum of 7 days, you will receive a notice confirming the successful receipt of your report. The recipient then decides on the next steps and whether follow-up actions need to be taken. Impartial bodies within our company may be consulted if necessary. Your identity will not be disclosed unless you wish it to be. If there are questions about an incident, the ombudsperson will contact you through your mailbox. Should you provide an email address, you will receive a notification about open inquiries in your mailbox. Investigating an incident can sometimes take several months, but you will receive an update on the measures taken within 3 months of submitting the report.

How and from what will I be protected after submitting a report?

If you submit a report and, at the time of the report, have sufficient reason to believe based on the circumstances and the information available that the matters you report are true, you will be protected from all retaliatory actions. By “retaliatory actions,” we mean any actions taken by the company as a result of a report which could lead to an unjustified disadvantage for you. This includes employment consequences such as:

• Termination
• Non-renewal of a fixed-term contract
• Failure to promote
• Adverse change in working conditions
• Redistribution of tasks
• Change of workplace or working hours
• Salary reduction, negative performance review
• Intimidation or defamation

Intentionally malicious or abusive reports are not covered by this protection and will be pursued by us.

How do I submit a report?

For submitting a report, please use exclusively the Submission form. There please describe the incident in as much detail as possible and, in addition, you have the option to provide information about yourself. The latter is completely optional and will be treated confidentially by the ombudspersons. It is essential that you note down the access data for your mailbox after successfully submitting the report, as otherwise, it will be irretrievably lost.

How does my mailbox work?

After successfully submitting a report, you will receive access credentials that you need to access your mailbox. You can use this to contact the ombudsperson if, for example, you remember something else later, or if the ombudsperson has questions for you. Once the ombudsperson has sent the final report, you can view it in your mailbox. If you provide an email address, you will receive automatic notifications when the ombudsperson sends a message or has created the report.