At Infineon we take data protection and confidentiality very seriously and adhere to the current national data protection regulations. Please read this data protection information carefully before submitting a report.
1. Purpose of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports submitted by you concerning infringements or violations against internal regulations.
In principle, this may be done in writing or over the telephone.
2. What should be reported and where can I seek advice?
Non-conforming practices from the following areas may be reported:
- Anti-competitive practices
- Conflicts of interest
- Handling of company property
- Handling of information and intellectual property
- Health and safety or environmental regulations
- I seek advice
You may use this system even if you have queries concerning Business Conduct Guidelines or would like to address an issue that does not belong to the given categories.
3. Responsible authority and data security
The authority responsible for data protection in the whistleblowing system is Infineon Technologies AG, Compliance Department, Am Campeon 1-12, 85579 Neubiberg, Germany.
This whistleblowing system is operated by a specialised company, Business Keeper AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Infineon.
Personal data and information entered into the whistleblowing system are stored in a high-security data centre in Germany operated by Business Keeper AG. Data inspection may only be carried out through Infineon due to established technical measures. Access to the data is restricted to a very small set of explicitly authorised persons of Infineon. Business Keeper AG and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
4. Type of personal data collected
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 Infineon, and
- the names of persons and other personal data of persons that you name in your report.
5. Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance Organisation of Infineon and always handled confidentially. The employees of the Compliance Department evaluate the matter and perform any further investigation required by the specific case.
Within the framework of processing a report or within a special investigation, it may be necessary to share reports with additional employees of Infineon e.g. if the reports refer to incidents in subsidiaries of Infineon.
If you report cases within the European Union/EEA, your personal data will be processed in accordance with European and applicable national data protection laws, in particular the German Federal Data Protection Act (Bundesdatenschutzgesetz). If you report cases outside of the European Union/EEA, your personal data will, if necessary, also be processed on-site by subsidiaries of Infineon in accordance with the regional data protection laws after inspection by the Compliance Department.
If legally required, we will forward your report on to the local law enforcement agencies.
All persons who receive access to the data are obligated to maintain confidentiality.
6. Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform a concluding evaluation. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
7. Using the whistleblowing system
Communication between your computer and the whistleblowing system takes place over an encrypted connection (SSL). Your computer IP address will not be stored during your use of the whistleblowing system. In order to maintain the connection between your computer and the whistleblowing system, a cookie is stored on your computer that merely contains the session ID (a so-called session 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 either online or by telephone within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. This allows you to submit reports to the responsible employee at Infineon either by name or anonymously, in writing or by telephone. The system does not generate any emails and the data can only be stored and read in the system.
8. Note on sending attachments
When submitting a report or an addition, you can send attachments to the responsible Infineon employee.
If you wish to submit an anonymous report, please take note of the following security advice:
Files can contain hidden personal data that could endanger your anonymity. Remove this data before sending. If you are unable to remove this data or are uncertain about 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.
In order to continue with the ongoing development of the system, Infineon may amend this data protection guideline at any time in accordance with data protection regulations.
I consent to the processing of my personal data by submitting a personalised report. If you do not consent to this, please keep your information anonymous.
Version: September 2017