During the use of BKMS® Incident Reporting, a text file (called a “session cookie”) is saved on your computer containing only the number of your session. This is necessary for technical reasons in order to establish the connection to a security-certified server. The “session cookie” does no damage to your computer, it does not access your data and has no relation to the contents of your report. If you close all browser windows after submitting your report, the “session cookie” will expire and be automatically deleted.
Please, help us to detect malpractice at Nordzucker. Speak up! We listen and care! Thanks a lot, your Nordzucker.
Nordzucker prioritizes lawful, sustainable and moral conduct. We take our company values – responsibility, dedication, courage and appreciation – very seriously. Consequently, we would like to encourage all of our employees, customers, suppliers and other interested parties to help us detect malpractice and illegal business practices.
Your report will help expose financial losses and image damage in a timely manner and you will ensure the sustainable success of the company.
Please, bear in mind that your information should be sufficient for an adequate investigation. That means the information is plausible, comprehensible and credible. You should substantiate and give reasons for your concern.
You should write the report in good faith, only. Reporting “in good faith” means that you believe that what you are reporting is true. Nordzucker does not expect you to have absolute proof of any misconduct or negligence that you report.
What is the process for submitting a report using a postbox?
To submit an anonymous or a personalized report, start by clicking the ”Submit Report“ button located at the top on our introduction page.
There are 4 steps to the reporting process:
You will be asked to read some information on the protection of your anonymity and to respond to a security query.
You will be asked about the category of your report.
You can elaborate on your report in your own words and answer questions about the incident by simply selecting responses. You can type into the free text field. You may also submit a file of up to 5MB to support your report. Please do bear in mind that documents can contain information about the author. Following the sending of your report, you will receive a reference number as confirmation that you have forwarded this report.
Please, subsequently set up your own secured postbox. You will receive feedback from us via this postbox, including information about the progress of your report.
If you already have a secured postbox, you can access it directly via the ”Login“ button.
As long as you do not enter any data revealing personal information, such as your function, age or address, the system will protect your anonymity.
How do I receive feedback and remain anonymous at the same time?
When setting up your secured postbox, please select your own pseudonym/ user name and password. Your report is kept anonymous through encryption and other special security routines. You will never be asked for personal information at any time during the reporting process. Do not submit any information that can be traced back to you. To ensure anonymity, please do not use a computer that has been provided by your employer to submit your report.
Via the secured postbox, an examiner will provide you with feedback on what is happening with your information or pose questions if details still need to be clarified - you will also remain anonymous during the dialogue. We are interested in reports to avoid damages to Nordzucker, not in you as a whistleblower.
The communication will be anonymous, unless you are willing to state your name. Nordzucker will not try to identify you. Handling of the report and any investigations will be done in a strictly confidential manner; this means that any information is disclosed on need-to-know basis only.
If you use the Speak Up system in good faith, Nordzucker guarantees you,
the right not to be dismissed
not to be subjected to any other detriment or to be victimised
Being a reporter does not automatically result in immunity. There are two exceptions when a reporter’s protection cannot be guaranteed, these are:
it is established that a report has been made in bad faith
if the report itself is a criminal offence
Do not use this SpeakUp system to submit false or slanderous statements or information knowingly. Please, act always responsibly.
District court of Braunschweig, HRB 2936 Company headquarters: Braunschweig
VAT identification number
Chairman of the Supervisory Board
Jochen Johannes Juister
Dr. Lars Gorissen (chairman) Axel Aumüller Alexander Bott
Data protection policy
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (Speak Up) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of Nordzucker AG. The processing of personal data in the Speak Up System is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to Nordzucker AG, its employees and customers. Nordzucker AG processes personal data (e.g. name) of employees who report an incident via the whistleblowing system solely based on the consent of the reporting employee.
The party responsible for data protection in the whistleblowing system is
Nordzucker AG and
companies in the Nordzucker Group
as parties with mutually autonomous responsibility (hereafter also: Nordzucker AG). The reporting system is operated by a specialised company, Business Keeper GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Nordzucker AG.
Personal data and information entered into the reporting system are stored in a database operated by Business Keeper GmbH in a high-security data centre. Only Nordzucker AG has access to the data. Business Keeper GmbH and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at Nordzucker AG.
Nordzucker AG has appointed a data protection officer. Questions on data protection can be sent to Maria Winther at firstname.lastname@example.org
Type of the collected personal data
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
your name, if you choose to reveal your identity,
whether you are employed at Nordzucker AG, and
the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Ethics Committee of Nordzucker AG and are always handled confidentially. The employees of the Ethics Committee of Nordzucker AG will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of Nordzucker AG or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
Rights of the data subjects
According to European data protection law, you and the persons named in the report have the right to access, rectification, erasure, restriction of processing of personal data and the right to object to processing of personal data concerning them. Your right to access information is limited to the extent that there are prevailing legitimate interest of a third party, e.g. of the reporting person to remain secret. If the right of objection is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required is deleted immediately. Where the processing is solely based on your specific consent you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. In addition, you have the right to lodge a complaint with a supervisory authority.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists or it is required by law. At the latest one month after the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the Speak Up System, a cookie is stored on your computer that merely contains the session ID (a so-called null cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen pseudonym / user name and password. This allows you to send reports to the responsible employee at Nordzucker AG either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible employee of Nordzucker AG. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.