Cefetra Whistleblower Policy
Our Cefetra Compliance Whistleblower System offers all employees, business partners, suppliers and their employees, people affected in our supply chain and third parties with a professional context a protected communication channel for queries and notifications concerning compliance issues. This whistleblower system is the ‘internal reporting point’ within the meaning of the Whistleblower Protection Act or comparable other national legislation within the EU and outside thereof.
All employees are expressly encouraged to approach their manager, Cefetra Legal & Compliance or the HR department if they perceive a lack of clarity regarding the rules in force, have questions in this respect or notice that the conduct of somebody working for the enterprise or of one of our business partners is dishonourable or conflicts with regulations. This procedure can prevent a small problem becoming a big issue. Questions and information to the responsible manager or the Cefetra Legal & Compliance or HR department should be made openly.
This whistleblower system is also the complaints procedure within the meaning of the Supply Chain Duty of Care Act. This should enable people to inform about human rights and environment-related risks and violations of human rights and environmental duties arising from the economic actions of our company in its own business field or of a direct supplier to our company.
Contact person
Would you like to contact us personally or have questions regarding compliance and notifications regarding possible compliance violations? Our email address is whistleblower@cefetra.com. Please note that confidentiality cannot be completely guaranteed if you make contact directly.
We prefer open communication in such matters. The first persons to approach are the relevant management or functional staff members. However, employees may approach the Legal & Compliance or HR department with questions or a notification at any time.
We also accept anonymous queries and notifications where whistleblowers prefer not to disclose their identity.
We follow up all notifications and do not tolerate any prejudicial treatment of persons who provide them. This also applies where notifications prove to be unjustified or unsubstantiated upon closer examination, unless such notifications contain deliberately or grossly negligently false information. If you provide an anonymous notification, it is technically impossible to identify you if the information you provide does not permit conclusions to be drawn as to your identity.
With the aid of the whistleblower system, the whistleblowers can:
- ask questions about compliance regulations and compliance issues, or
- inform the enterprise online about matters indicating possible breaches of regulations or dishonourable conduct (e.g., corruption, violations of human rights or environmental regulations) on the part of the enterprise and/or its employees, about weaknesses in procedures, areas of risk and possibilities for improvement
- provide information about human rights and environment-related risks and violations of human rights or environmental duties in our supply chain.
Your query or your notification is initially received by Group Compliance.
The person handling the case will first assess whether it is a query seeking advice which can be answered immediately and will send you a corresponding response via the communication channel you selected. In an individual case it might be necessary for the person handling the case to pose further questions in order to correctly understand and respond to your query.
Whether it is notification of possible misconduct, a weak point or potential for improvement that requires further assessment. The person handling the case will initiate further appropriate measures in accordance with the relevant procedures provided for within the enterprise.
The exchange of information via the whistleblower system takes place completely in encoded form. It is not possible for unauthorized persons to view the contents.
When submitting your query or your notification, you can choose to remain anonymous or to provide your contact data. If you wish to remain anonymous, it is not possible to identify you unless the information you provide permits conclusions as to your identity.
The whistleblower is subject to the special protection regulations of the Whistleblower Protection Act, provided that, at the time of the notification, the whistleblower had sufficient grounds to assume that the informed he or she was reporting was true and that the information concerned violations that fall under the area of application of the Whistleblower Protection Act (criminal offences, certain administrative offences), or, at the time of the notification or disclosure, the whistleblower had sufficient grounds to assume that this was the case.
The whistleblower shall not be protected if the notification deliberately or grossly negligently contains incorrect information (false report). In this case, the whistleblower shall be required to compensate for the damage incurred (Article 38 Whistleblower Protection Act).
If you wish to receive a response to your query or notification without disclosing your identity, then identify this in the email.
After verifying matters, the person handling the case will inform you about the further sequence of events, insofar as possible
Yes, it is possible to attach files or images to information.
The whistleblower system immediately transmits confirmation of receipt to you as soon as your query or your notification has arrived on our server.
If you wish to have a personal meeting, kindly identify this in the email so that the person handling the case can contact you to arrange the details. Please provide a brief description as to where and how you would be able to attend a personal meeting.
If your query or your notification about the discovery of breaches of the rules by you personally means that you incriminate yourself, this will not protect you subsequently against the appropriate measures under employment law or against possible consequences under criminal law. However, when deciding such matters, the contribution by a person whose information leads to the discovery of breaches of the rules and to the prevention of further risks, can be taken into account.
Yes.
Messages you dispatch will be stored within the whistleblower system, as will an assessment of both the relevant sector of the enterprise and the significance of the notification. In addition, communication with you via the “digital letterbox” will be stored within the system, as will the processing comments of the case worker, any measures implemented, and conclusions drawn during the further handling of the case.
Insofar as personal data is processed within this procedure, this will take place within the framework of data protection regulations. The automatic communication of stored data to third parties is not supported technically and does not take place.
On the one hand, they are informed to the extent required by law and, on the other hand, for reasons of fairness since in dealings with our employees we prefer to place our cards on the table.
No.
Both the person handling the case of your query or notification and any other persons involved in processing it within the company are subject to a confidentiality obligation. This means that nobody who is not involved in processing the notification or query can inspect it nor the relevant research results.
Yes.
The enterprise is under an obligation to investigate all alleged breaches of compliance in a reasonable manner. For this reason, all notifications about misconduct, weak points and potential for improvement, and if appropriate queries requesting advice, are verified accordingly. Otherwise any notification you submit would be futile.
If you provide detailed information about the matter concerned or attach documents to your notification, you should be aware that this might ultimately enable your identity to be discovered.
Yes.
Within the context of their investigative powers, government authorities have access to all information within the enterprise. Within the context of investigative procedures, on the basis of court orders, these authorities are entitled to demand the surrender of all documents and materials within the enterprise that relate to a certain matter, and may also conduct a search. The enterprise may avert such orders of seizure and search measures by surrendering the relevant documents and materials.
In individual cases, this includes any information on a certain matter within the whistleblower system.