Report violations (HinSchG)
Whistleblowing system
1. POLICY
Sustainable business practices create long-term prospects for the environment, society and the economy, as well as for every individual employee and business partner of HIRMER GROSSE GRÖSSEN. The cornerstones of the HIRMER GROSSE GRÖSSEN culture are the allocation of key responsibilities and their independent implementation and management, together with a shared understanding of values and risk mitigation for sustainable corporate development. The whistleblowing system with legal expertise provided by Ratisbona Compliance GmbH (“RC-Whistle”) offers an accessible, clearly defined structure and a legally sound initial assessment. This creates additional trust and security for reporting misconduct, thereby helping to safeguard the sustainable success of Hirmer Grosse Grössen Online GmbH and prevent harm.
2. SCOPE
a) This policy describes the procedure for reporting confirmed or suspected misconduct or wrongdoing.
b) It applies to all employees (including temporary workers), customers, suppliers, and anyone with an interest in the well-being of the company.
3. KNOWLEDGE OR REASONABLE SUSPICION OF MISCONDUCT
a) We encourage any employee who knows of or has reasonable grounds to suspect significant misconduct or wrongdoing (a breach of the law or unethical conduct contrary to our Code of Conduct) to submit a report.
b) We encourage all employees to report such matters through the known and established reporting channels. These are:
i. Trusted contact person
ii. Human Resources
iii. Works Council
iv. Management
c) If none of these reporting channels is suitable for your report, you may use the Ratisbona Compliance whistleblowing system with legal expertise. The Ratisbona Compliance whistleblowing system is operated by an independent third party.
d) Reports submitted through the Ratisbona Compliance whistleblowing system are sent directly to Ratisbona Compliance. Reports may be submitted digitally via Ratisbona Compliance’s reporting platform, by telephone, or in person.
4. DELIBERATELY FALSE REPORTS
Deliberately false reports are considered a breach of the Code of Conduct and will be treated accordingly. They may result in disciplinary action and/or criminal prosecution.
5. ASSIGNMENT OF RESPONSIBILITIES
a) The Ratisbona Compliance whistleblowing system enables anonymous communication with the reporting person and ensures it where required. After a report of alleged misconduct or fraudulent conduct is received, the matter undergoes an initial review based on the information provided.
b) Ratisbona Compliance is responsible for reviewing and processing incoming reports within the prescribed time limits.
c) Follow-up questions may be put to the reporting person for further assessment of the matter while preserving their anonymity.
d) The next steps for handling the matter are determined on the basis of this initial review. Depending on the seriousness of the allegation, the persons involved, and the relevant area of law, the report will be forwarded to the responsible body within the affected affiliated company or group of affiliated companies. External experts may be consulted during the further investigation of the misconduct. Where there is sufficient suspicion that a criminal offence has been committed, there may be an obligation to notify the authorities. Ratisbona Compliance ensures that all reported cases are investigated, adequately documented, and brought to a conclusion.
e) Hirmer Grosse Grössen Online GmbH expects managers and supervisors at all levels of the hierarchy to take such reports seriously, treat them as strictly confidential, and investigate them promptly in accordance with the applicable requirements and necessary measures so that the misconduct can be remedied.
6. NO FURTHER ACTION ON A REPORT
a) insufficient information is available for an adequate investigation and there is no possibility of obtaining further information; or
b) the report is demonstrably false.
7. REPORTING
Reporting is carried out by Ratisbona Compliance’s Legal Department. Detailed reports are prepared for cases investigated by Ratisbona Compliance.
8. PROTECTION AND RIGHTS OF REPORTING PERSONS
a) The identity of all reporting persons is treated as strictly confidential. Under no circumstances will Ratisbona Compliance disclose voice messages, IP addresses and/or telephone numbers unless section 8(c) applies.
b) No person who submits a report need fear negative consequences as a result. However, reporting persons (whistleblowers) are not protected in respect of their own misconduct.
c) The protection of the reporting person is not guaranteed in the following cases: i. At the request of authorities such as law-enforcement agencies, Ratisbona Compliance is required to provide voice messages, IP addresses and/or telephone numbers. ii. Cases in which reports are found to have been deliberately false, made in the knowledge that they were untrue, and/or made in bad faith. iii. Cases in which the report itself must be classified as a criminal offence or a breach of the Code of Conduct (for example, defamation or threats).
d) If the reporting person disagrees with the outcome of the investigation, they may raise the matter again through the Ratisbona Compliance whistleblowing system with legal expertise.
9. PROTECTION AND RIGHTS OF ACCUSED PERSONS
a) If an investigation is initiated as a result of a report, Hirmer Grosse Grössen Online GmbH will inform the persons concerned within 30 working days at the latest. This period may be extended after considering the circumstances of the individual case, for example where there is a risk that evidence may be destroyed or the investigation otherwise obstructed.
b) Persons concerned have the right to complain about investigations directed against them. They should contact:
i. Their supervisor or managing director
ii. Ratisbona Compliance; contact details can be found at the end of this policy.
10. DATA PROTECTION
Ratisbona Compliance will treat all information as strictly confidential. The data of both reporting persons and persons concerned will be protected within the statutory framework. Access to information—both its content and the persons involved—will be restricted on a need-to-know basis. This policy requires personal data to be processed and stored. This will be done exclusively in accordance with applicable data-protection law.
11. RATISBONA COMPLIANCE REPORTING PROCESS
ONLINE REPORT
Before submitting your report through our system, please read the privacy information for whistleblowers: https://ratisbona-compliance.de/datenschutzerklaerung-fuer-hinweisgeber/ By clicking the “Submit a report” link, which takes you to the whistleblowing system’s submission form, you confirm that you have read and understood the privacy information.
REPORT BY TELEPHONE
Would you like to submit your report by telephone? You can reach the team of attorney Erich J. Beer at:
+49 941 2060384-2
IN-PERSON MEETING
Would you like to make a report in person?
Please contact us at:
Ratisbona Compliance GmbH
Trothengasse 5, 93047 Regensburg
T +49 941 2060384-1
www.ratisbona-compliance.de