1. Why should a whistleblowing report be provided?
A positive and open corporate culture includes compliance with legal and internal company rules.
You may be aware of harmful behavior or risks that endanger the company. By reporting such risks, you will help to uncover such risks at an early stage and prevent potential financial and reputational damage to our company and third parties.
2. What information can be provided here?
Reports on serious violations of legal and internal company rules that affect our company can be submitted here, especially in the following areas:
- Corruption
- Competition offenses / violations of antitrust law
- Theft / fraud
- Violations of data protection regulations
- Money laundering
- Conflicts of interest
- Human rights / occupational health and safety
Reports via this system are one way of informing us of possible compliance violations. Alternatively, reports can also be made to superiors or directly to the Compliance department.
2. Where do you report to?
Your electronic report is sent anonymously and encrypted to our external ombudsperson:
Dipl.-Ing. Hans-Detlef Krebs
Link (german):
https://whistleblowing-crfe.cloud-works.de/#/
If you would like to send a message, click on the „Submit“ button at the top.
- If you would like a personal meeting (by telephone or web conference), please mention this in the digital message. We will be happy to provide you with a protected voice channel.
- You will first be asked to read an information text to protect your anonymity.
- On the report page, you will privide your report in your own words and answer a few predefined questions about the case via check boxes and free text fields. You can also send files to support your report, but only once you have logged into the system again. Remember that documents may contain information about authors. After submitting your report, you will receive a reference number (16 digit receipt) as anonymous information to keep in touch with the ombudsperson. Now you have created your anonymous mailbox for this specific case.
If you already have a protected mailbox, you can access this mailbox directly via the login field with your reference number (16 digit receipt).
As long as you yourself do not enter any data that could be used to identify you, the system technically protects your anonymity.
We assure you that we are only interested in the case you have reported. The aim is to uncover irregularities and avoid financial losses.
The overriding principle of the process used here is the protection of the person providing the information. The functionality of the anonymity protection is certified by an independent body.
When you set up your secure mailbox, you received reference number (16 digit receipt) as an identification feature for your anonymous mailbox. You should not provide this reference number to anyone. If you lose your reference number, please submit a new notification and set up a new mailbox. If possible, please provide a reference to your old message. This is a new mailbox, the contents of your old message will not be available here.
Your report will be kept anonymous by encryption and other special security routines. If you submit your report anonymously, you do not have to provide any personal details. Do not enter any data that could be used to identify you. If possible, use a private technical device (e.g. PC, laptop, smartphone) to protect your anonymity as much as possible.
Via the protected mailbox, a contact person will give you feedback on what is happening with your report or ask questions if details are still unclear – you will remain anonymous during the dialog. We are interested in reports to prevent damage, not in your identity as whistleblower.
Our company will check the plausibility of every report without delay. If the information appears plausible, the matter must be investigated immediately and objectively. Statutory deadlines are considered. If possible, the whistleblower will be given prompt feedback.
Internal investigations and inquiries may only be carried out if there is sufficient initial suspicion based on specific circumstances with a connection to the company. Investigations are conducted with the greatest possible confidentiality and in compliance with data protection and anonymity.
As part of the investigation and prosecution of actions that could harm our company or its employees, the interests of the company and its employees must be protected.
- whistleblower, in particular the protection of anonymity and protection against disadvantages
- employee from false reports and
- company, in protection against risks and damage,
Whistleblowers should report recognized violations. This applies equally to well-founded suspicions. Reports can be made anonymously and non-anonymously.
Whistleblowers who report a complaint are also requested to describe the facts as precisely as possible and – if possible – to provide evidence to substantiate the suspicion.
Any discrimination against the person providing the information based on the provision of information is prohibited.
Abuse of the whistleblower protection system (e.g. by intentionally making a false report) is prohibited and will be penalized. Reports made in good faith will not result in liability or sanctions, even if they later turn out to be incorrect.
The whistleblower protection system has been certified by proven and independent experts for data security and data protection. It is operated in a high-security data center in Germany. Administration and maintenance of the servers is the sole responsibility of the employees of the data center, who are not able to access the content of the reports due to the end-to-end encrypted connection and the encrypted database. The incoming reports can only be viewed by the ombudsperson. Access to the reports by unauthorized third parties, the computer center or the platform operator is avoided by technical measures.
The information according to Art 13/14 GDPR can be found at the following link: Informationspflichten – Carl Remigius Fresenius Education Group (crf-education.com)