Why should I submit a report?

Compliance with legal, social and internal rules is a vital part of a positive and open corporate culture.

Perhaps you are aware of harmful behavior or risks that endanger our company or violate the rights of individuals. Your information could contribute to the well-being of our employees and business partners, and help reveal possible financial damages or harm to our image at an early stage. It is vital to ensure that our company is able to investigate such reports in a rapid and objective fashion.

This online whistleblowing system is available to employees as well as third parties to report possible compliance violations. Reports of actual or suspected violations of laws or other misconduct and shortcomings can be submitted via this platform confidentially and, if desired, anonymously.

What kinds of reports can I make via the whistleblowing system?

You can submit reports on violations relating to the following topics:

• Corruption / bribery
• Data protection and IT security
• Theft / fraud / breach of trust
• Antitrust and competition law
• Capital market law
• Contract and licensing law
• Serious violations of the Code of Conduct – principles of social responsibility
• Sexual harassment in the workplace

You can also seek advice on all compliance matters instead of submitting a formal report.

Explanations and examples of the possible topics for a report will be provided during the reporting process.

Please note: The system 1) may not be used to knowingly submit false or defamatory reports or information, and 2) is not an emergency call system.

When should I submit a report?

If possible, you first should take your concerns to people in your immediate working environment, such as your supervisor, the company management, the human resources department or – if present – the works council. Your Compliance Officer is also available to discuss concerns in a personal meeting, via phone or email.

If you have already exhausted these options or they are not applicable to your situation, you may use this whistleblowing portal to report potential significant violations or ask for advice.

Especially with regards to serious or ongoing misconduct, please submit a report as soon as possible, so that we can guarantee a quick clarification and stop persistent wrongdoing.

What is the process for submitting a report and how do I set up a postbox?

If you would like to submit a report, click on the button on the upper left of this page "Submit report or seek advice".

The reporting process has four steps:

1. First you are provided with information about the technical precautions with which this whistleblowing system protects the security of your data.
2. In the second step, you are asked about the topic of your report.
3. On the report page, you will compose your report in your own words and answer questions about the case. In the free text field, you have about as much writing space as a full page. You may also submit a file of up to 10 MB to support your report. After submitting your report, you will receive a case number as confirmation that you have submitted the report.
4. You can then set up your own postbox. An examiner will provide you with feedback via this postbox informing you about what is happening with your report or asking questions should any individual points be unclear. By setting up a postbox, you will be able to actively assist with the investigation.

If you have already set up a postbox for your report, the "Login" button will take you directly to this postbox.

As long as you yourself do not disclose any personal data that allows us to identify you, the BKMS^® system technically protects your anonymity.

We assure you that we are only interested in the case you report.

How do I receive feedback and remain anonymous, if desired?

By setting up a secured postbox. When setting up your postbox, you will select a pseudonym and password. Your report is kept secured by encryption and other special security routines. If you wish to remain anonymous, do not enter any data that permits conclusions to be drawn about your identity.

The BKMS^® system places the utmost importance on protection of the whistleblower. The technical measures protecting the confidentiality of the data are certified; we are happy to send you the corresponding certifications upon request.

What is the process for an investigation?

The investigation of the case will be led by the Compliance Officer. After an initial credibility check, this person will take all necessary steps to investigate the case if there are sufficiently concrete indications that a reported misconduct and shortcomings may exist.

In exceptional cases, the Compliance Officer can include other internal and / or external parties if this is indispensable for the investigation of a specific report. Every person who receives access to the data will be obligated to handle these data confidentially in order to ensure that everything is done as discreetly as possible. To protect the affected employees, the group of parties and individuals involved in the investigation will be kept as small as possible.

If a report makes accusations against individual employees, exonerating circumstances will be equally taken into account in the investigation along with any incriminating circumstances. The competent parties are guided by the principle that the presumption of innocence remains in effect until misconduct by an employee has been actually proven.

The investigation will be carried out as discreetly as possible. The whistleblower will – if known or via the postbox – always be informed of what has resulted from the report.