BKMS System
Penguin Random House Integrity & Compliance
Cookies are disabled in your browser.
Please enable cookies to use the BKMS® System.
For more information about cookies, please click here.
 

The secure way to seek advice or report substantive misconduct

Penguin Random House makes this internet-based system for reporting compliance-related concerns (BKMS® System) available to employees and others who may want to seek advice or report substantive violations of the Code of Conduct.

If possible, you should first try to address your concerns with those in your immediate work environment. For example, you can bring up your concerns with your supervisor, senior management, human resources or legal department. If you are uncomfortable raising concerns directly with your manager or another person in your business unit or if your previous attempts to raise these concerns have not yielded results, this internet-based reporting system is a good way to raise your concern.

This internet-based reporting system allows you to raise concerns freely and without fear of retaliation. Reports are treated with the greatest possible regard for confidentiality and in compliance with data protection requirements. Employees who raise workplace concerns need not fear harassment or retaliation. All workplace concerns should be raised in good faith. Raising workplace concerns “in good faith” means that an individual making a report believes that what he or she is asserting is true, whether or not subsequent investigation proves what they have asserted to be true. It is prohibited to abuse this system by knowingly submitting false or slanderous information.

We encourage users of this system to provide their name. We will take all reasonable steps to treat reports in a confidential manner. Please see "Privacy Statement" on the left side of the page for more complete information on how your report will be handled.

In addition to this online reporting system, Penguin Random House makes available to you other options for seeking advice and reporting concerns. Information on a additional contact persons for discussing compliance-related is available at http://employee.penguinrandomhouse.com/ethics.

If this is your first time using this system, please click here:
If you have already set up a postbox, you may login here:
  • Why should I submit a report?

    A positive and open corporate culture requires that legal, societal and corporate standards are upheld.

    Perhaps you are aware of harmful acts or risks that are endangering the company. Your report can help expose damage to the finances and image of the company at an early stage. Doing so helps ensure the sustainable success of the company and the continued existence of the jobs it creates.

  • What kinds of reports can I submit?

    Information regarding substantive violations of the Code of Conduct, will be accepted and forwarded by this online reporting system. Please see the Code of Conduct at at http://employee.penguinrandomhouse.com/ethics.

    Penguin Random House values an open corporate culture. Management at all levels is obliged to encourage an open dialogue and to support employees who bring concerns to their attention.

    In the case of minor grievances that do not constitute a direct violation of the Code of Conduct, employees should seek out resources in their immediate work environment (supervisors, senior management, human resources, etc.).

    It is prohibited to abuse this system by knowingly submitting false or slanderous information.

  • How do I submit a report? What is a postbox and how do I set up one?

    To submit a report, start by clicking the “Submit report or ask advice” button located on the top left side of the home page.

    The reporting process consists of four steps:

    1. You will receive information about the technical measures with which this online reporting system guarantees the security of your data.
    2. In the second step you will be asked to indicate the type of report you will be making.
    3. On the Report Page you will be asked to use your own words to describe the incident you are reporting – using no more than 4,096 letters (the amount of text that would normally fit on a full sheet of paper). In addition, you will be asked to answer some specific questions. You may also submit smaller files of up to 2MB to support your report. After you have submitted your report it will be given a case number as proof that you have filed a report. Please keep this case number in a secure and private location as you may need it for future correspondence.
    4. Finally, you will be asked to set up your own postbox. This postbox will be used to communicate with you, to answer your questions and to keep you informed as to the status of your report. You must select your own personal pseudonym and password in order to create the postbox. Encryption and other special security procedures are employed by the system to ensure that your submission remains secure at all times.

    Once you have established a postbox you will be able to access it via the Login button.

  • How can I receive feedback?

    The foremost purpose of the BKMS® System is to protect the whistleblower. The technical provisions guaranteeing the confidentiality of the system’s data are certified and can be verified by you at any time.

    You select your own personal pseudonym and codeword that you use to establish your post box. Encryption and other special security procedures are employed by the system to ensure that your submission of information remains secure at all times.

    An Ethics & Compliance specialist will contact you via your post box to provide information about the status of your report or to ask you further questions if certain details need to be clarified.

  • Privacy Statement

    BERTELSMANN takes the topic of data protection and confidentiality very seriously. We 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.

    Responsible party

    The party responsible for data protection in the whistleblowing system is

    Bertelsmann SE & Co. KGaA
    Carl-Bertelsmann-Straße 270
    33311 Gütersloh, Germany
    Telephone: +49 (0) 5241-80-0
    Fax: +49 (0) 5241-80-62321
    Email: info@bertelsmann.de

    The data protection officer of Bertelsmann SE & Co. KGaA (hereafter: BERTELSMANN) can be reached at the above postal address with the addition "To the Data Protection Officer" or at the email address: data-privacy@bertelsmann.de.

    Type of the collected personal data

    Use of the whistleblowing 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 BERTELSMANN and
    • the names and other personal data of persons whom you list in your report, if applicable.

    Purpose and legal foundation of the data processing

    The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules of BERTELSMANN. The processing of personal data within the framework of the BKMS® System is based on the justified interest of our company in discovering and preventing abuses and thereby averting damage to BERTELSMANN, BERTELSMANN group companies, employees and customers. The legal foundation for this processing of personal data is therefore Article 6 paragraph 1 f) EU-GDPR.

    Confidential handling of reports

    Incoming reports are received by a small selection of expressly authorized and specially trained employees of the Compliance Organisation of BERTELSMANN and always handled confidentially. The designated employees of the BERTELSMANN Compliance Organisation evaluate the matter and perform any further investigation required by the specific case.

    While processing a report or conducting a special investigation, it may be necessary to share reports with additional employees of BERTELSMANN or employees of other BERTELSMANN 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 about the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports and that the consent of the report submitter is obtained before sharing a report with employees of BERTELSMANN group companies for processing of the issue. All persons who receive access to the data are obligated to maintain confidentiality.

    Information about the accused

    We are legally obliged to inform accused parties of any reports received against them as soon as the disclosure of this information no longer jeopardises the investigation. Your identity as a whistleblower will not be disclosed unless we are legally bound to do so .

    Rights of the data subjects

    Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure, restriction of processing and right to object to the processing of your personal data. If the right to object to the processing of the personal data is invoked, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer required will be deleted at once. If you would like to make use of your right to object, please contact the address listed under item 1.

    You also have the option of contacting a data protection authority and submitting a complaint there. The competent authority for our company is the

    State Representative for Data Protection and Freedom of Information of North Rhine-Westphalia
    Kavalleriestr. 2-4
    40213 Düsseldorf
    Phone: +49 (0) 211/38424-0
    Fax: +49 (0) 211/38424-10
    Email: poststelle@ldi.nrw.de

    However, you can also contact the data protection authority responsible for your place of residence.

    Automated decision-making

    No automated decision-making takes place with regard to the processing of your personal data described here.

    Profiling

    No profiling takes place.

    Retention period of personal data

    Personal data are retained for as long as necessary to clarify the situation and issue a final assessment of the report or until existing contractual and/or legal obligations are met, unless overriding statutory retention periods prevent erasure of the data. The same applies if you have revoked your consent.

    Updating of the privacy policy

    If this privacy statement is modified, notice of this change will be published on the website and in other suitable locations.

    Date of privacy statement: June 2018