Welcome to the ZF Trustline

Compliance with the applicable laws and the internal guidelines of the company, as well as resulting behaviour that is lawful and proper, is of the highest priority at ZF.

The ZF Trustline supports this priority, allowing employees, customers and business partners to submit reports (anonymously, if desired) regarding potential compliance violations in identified categories. These reports allow us to protect against behaviour that is damaging to the business, reputation and employees of ZF.

You can make good faith reports concerning potential violations in the following categories:

Violation of antitrust law

Violations of laws designed to ensure and maintain a proper competition in the market by protecting trade from abusive practices such as anti-competitive agreements between competitors and monopolization.

Corruption and bribery

Corruption can be defined as dishonest or fraudulent conduct by a person in power, typically to achieve an improper benefit. One form of corruption is bribery. Bribery includes the improper use of gratuities, such as gifts, entertainment and hospitality, in exchange for improper gain. Corruption can be committed both actively (such as asking, offering, promising or granting an improper gratuity) and passively (such as acceptance of improper gratuities).

Conflict of interest

A conflict of interest is a situation where a person or company is involved in multiple interests, and one or more of these interests could possibly corrupt the motivation or decision-making of that person or company. For example, a conflict of interest includes a situation in which an employee has a personal interest, especially economic, that could possibly influence or interfere with the employee’s job responsibilities.

Fraud and financial reporting concerns

Fraud can be defined as wrongful or criminal actions that are intended to deceive others in order to result in improper personal or financial gain. Fraud can include the intentional distortion of facts to others in order to induce them to grant benefits to the person behaving fraudulently. Fraudulent actions can include actions taken to benefit the individual or the company.Financial reporting concerns comprise any activity that is in violation of generally accepted accounting principles and thereby violates financial reporting policies or practices of the company. Financial reporting concerns can include improper reporting or accounting of items, causing misrepresentation on the company’s books and records.

Employment-related matters

Violations of national employment law in the country where you work, company policy, or negotiated terms and conditions of employment. This can include claims of mobbing, harassment, discrimination, compensation, or violations of specific company policy.

Other material violations of policies or law

This category is for other materials violations of ZF policies or laws. This includes crimes, violations and breaches that put ZF at risk of signification financial loss or serious reputational damages.

As examples, topics can include material violations that relate to: money laundering laws, export control and customs laws, theft, blackmail, spying or sabotage, bankruptcy laws, and product compliance topics.

In addition, violations of occupational health and safety regulations, such as laws that protect employee safety, can constitute a criminal offense and serious violation for ZF. Also, violations of environmental protection laws and regulations can pose a serious threat for ZF, such as environmental pollution and improper handling of hazardous waste.

To submit an anonymous or personalized report, start by clicking the "Submit report" button located on the top left side of the introduction page.

There are 4 steps to the report process:

• First, you will be asked to read some information on the protection of your anonymity and to respond to a security query.
• Second, on the following page, you will be asked about the category of your report.
• Third, on the report page, you can elaborate on your report in your own words and answer questions about the incident by simply selecting from available responses. The reporting system allows you to type up to 4,096 characters into the free text field. You may also submit a file of up to 10MB to support your report. Please keep in mind that files may contain identifying information about the author. Once you submit your report, you will receive a confirming reference number.
• Finally, you will be given the opportunity to set up your own secured postbox. This will allow you to communicate with us via this postbox, including answers to questions and information about the progress of your report. You may use this secured postbox on an anonymous basis.

Should you already have a secured postbox, you can access it directly via the “Login” button on the ZF Trustline introduction page.

As long as you do not enter any data that could reveal your identity, the BKMS® System used by the ZF Trustline protects your anonymity from a technical perspective.

We encourage you to provide as much detail as possible in your report, and remind you that reports should only be made in good faith.

The BKMS® System used by the ZF Trustline places the utmost importance on the protection of the whistleblower.

When submitting a report, you will be given the opportunity to set up a secured postbox. When setting up your secured postbox, you will select a user name and password yourself. Your report is kept anonymous through encryption and other special security routines. You are not required to give any personal details at any time during the reporting process should you not wish to do so. If you wish to remain anonymous as part of the reporting process, do not submit any information that can be traced back to you, and if possible avoid using PC's for your report that are provided by ZF.

As part of the report handling process, the secured postbox will be used to provide any feedback or to ask any necessary follow-up questions. Using the secured postbox, you will remain anonymous during this dialogue. This allows us to focus on the report contents. Depending on the subject matter of the report, various different departments at ZF may be involved to look into and/or handle a report, and may also communicate with you via the secured postbox. If the report was made anonymously, then the report will remain anonymous as part of the involvement of these various departments.