Reporting undesirable developments is important for early detection of risks

Why should I submit a report?

The Incident Reporting System is for early detection and avoidance of undesirable developments which could result in considerable risks for Schaeffler and its employees.

If you send us a report, you will be helping to discover and prevent undesirable developments.

Which cases can you report?

Reports about violations relevant to compliance which could cause considerable damage to Schaeffler and its employees will be accepted and processed.

The possible categories for a report are:

• Corruption / bribery / accepting bribes
• Fraud / breach of trust / major theft / embezzlement / forging of documents
• Violation of tax or customs regulations
• Infringements of Competition or Anti-Trust Laws
• Violation of Company Secrets
• Conflict of Interest
• Data privacy violations
• Money laundering / Financing of Terrorism
• Environmental damages
• Human rights
• Sanctions and embargo violations
• Violation of the Schaeffler Group Code of Conduct or Schaeffler Group Supplier Code of Conduct / other compliance-relevant notices
• Violation of Binding Product-Related Commitments (Technical Compliance)

Before sending a report, we expect you to check it carefully and to the best of your knowledge and belief, to ensure that any information with regard to charges of illegal or unlawful behavior is well-founded, and that a report is necessary.

This Incident Reporting System may not be misused for reporting obviously unfounded accusations and denunciations (in the sense of criminal law provisions such as slander or libel).

How does a report work? How do I set up a postbox?

To submit an anonymous or personalized report, start by clicking the “Submit Report” button located on the top left side of our information page.

The reporting process consists of four steps:

1. First, you will be asked to read some information on the protection of your anonymity and to respond to a security query.
2. On the following page, you will be asked about the category of your report.
3. On the report page, you can elaborate on your report in your own words and answer questions about the incident by simply selecting responses. In the free text field, you can write 5,000 characters, which corresponds to a full DIN A4 page. You may also submit a smaller file of up to 5MB to support your report. Please remember that documents can contain information about their author. After you have submitted your report, you will receive a reference number as proof that you submitted this report.
4. Finally, you will be asked to set up your own secured postbox. You will receive feedback from us via this postbox, we will answer your questions and keep you posted on the status of your report.

If you already have a secured postbox, you can access it directly via the "Login" button. Here as well, you will first have to answer the security query.

As long as you do not enter or attach any data that could reveal your identity, the BKMS^® System protects your anonymity from a technical perspective.

We assure you that we are only interested in the case you have reported to us. Undesirable developments should be revealed in order to prevent considerable damages.

How do I receive feedback and still remain anonymous?

The BKMS^® process places top priority on protecting the whistleblower. The protection of anonymity function is certified and can be checked by you at any time.

When setting up your secured postbox, you select a username and password. Your report is kept anonymous through encryption and other special security routines. You will never be asked about personal details at any time during the reporting process. Do not submit any information that can be traced back to you. If you have doubts about using the PC at your workplace, you can also send us a report from a private PC. Irrespective of this, we assure you that if you use a work telephone or a PC provided by the employer we will not attempt to trace the report back.

An employee here will give you feedback about what is happening to your report, or ask you questions if there are any unclear details, via your secured postbox. You will also remain anonymous during the dialogue.

Further information on the Schaeffler whistleblowing system and complaint mechanism

Right to choose between internal and external reporting office

The German Whistleblower Protection Act ("HinSchG") provides that the whistleblower can choose whether to file a report either with a Schaeffler internal or an external reporting office related to alleged violations of laws or regulations as defined in § 2 HinSchG. However, it also stipulates that whistleblowers should give preference to the internal reporting office in cases where effective internal action can be taken against a violation, and if they do not fear reprisals.

Schaeffler has established such an internal reporting office at the level of Schaeffler AG in form of the Compliance Forensics & Investigations ("F&I") department, which receives reports of violations, maintains contact with the whistleblowers, investigates the allegations and develops and communicates measures to remedy them. The governing principle for all reports is confidentiality, especially with regard to the identity of the whistleblower. Investigative actions, that may lead to the disclosure of the identity of the whistleblower, are priory aligned with the whistleblower. Reprisals against whistleblowers may constitute a violation of law itself that will be followed up by F&I and may in turn lead to sanctions against the relevant employees and managers.

An external reporting office is envisaged at the Federal Office of Justice (BfJ). It is to be responsible for the Federation and the Federal States and receives reports both from the private and the public sector. In special areas of responsibility, the Federal Financial Supervisory Authority (BaFin) and the Federal Cartel Office (BKartA), with their already established whistleblower systems, are to function as external reporting offices with special responsibilities. In addition, the Federal States can set up their own reporting offices.