Employees, business partners and external parties have the right to report circumstances that indicate a breach of the law or our internal rules. This information can be reported to the ombudsman. The ombudsman offers a legally protected and confidential service outside the company. It informs whistleblowers about their rights and how the information they provide will be handled. The ombudsman will only share this information with its contact at the company if the whistleblower [1]  consents to this. The ombudsman can be asked to act as a representative in the matter. The ombudsman is always available for the whistleblower to contact.

[1] Any gendered terms always include people of all genders. The HRS Group is committed to the Diversity Charter and considers everyone to be equal, regardless of gender, age, background, religion, disability or sexual orientation. The wording of this text has been chosen solely to make the text easier to read.

All employees and external parties, such as suppliers or service providers, can contact the ombudsman.

The ombudsman accepts information regarding breaches of the law and our internal rules. The main objective is to investigate and prevent economic offenses, accounting offenses and financial losses. However, any violation of internal policies such as the Code of Conduct can also be reported to the ombudsman. Confidential and anonymous reports of discrimination, sexual harassment or similar issues can also be submitted to the ombudsman.

Yes. The whistleblower alone decides what information to provide to the ombudsman and what information the ombudsman can pass on to the company in the second step of the process. The ombudsman is only permitted to pass on information against the wishes of the whistleblower in cases of misuse, i.e. if the whistleblower has intentionally provided incorrect information. The ombudsman will make this clear upon initial contact with the whistleblower.

No, the ombudsman is free of charge.

Yes, whistleblowers can contact the ombudsman anonymously. This includes the whistleblower’s initial contact with the ombudsman. If the whistleblower prefers, the ombudsman will then maintain the whistleblower’s anonymity when dealing with the company.

The information is investigated while taking into account the relevant laws and internal rules, and the wishes of all parties concerned (e.g. the anonymity of the whistleblower). To this end, the ombudsman will check the information provided, before forwarding it to its contact at the company.

Whistleblowers can find out the status of the investigation from the ombudsman at any time. The ombudsman will share as much information about its findings with the whistleblower as is legally permitted, at the latest after the completion of the investigation.

No, the ombudsman is not permitted to represent the whistleblower in any official or judicial proceedings. Therefore, the Ombudsman cannot and must not take any steps to enforce the individual rights or claims of the whistleblower in court.

Yes. The ombudsman acts as a standalone, independent lawyer and is not subject to any instructions from the company regarding the content of the matter. After a thorough investigation, the ombudsman decides whether and to what extent the information submitted to it can be passed on to the company.

Initial contact with the ombudsman can be made by telephone, email, SMS, post or in a face-to-face conversation. An online service is also available.

Yes. All employees will continue to be able to contact their managers, the Compliance department (anonymity and confidentiality is guaranteed) and the management team.

Yes. Whistleblowers are always protected. Any retaliation against whistleblowers will not be tolerated.

Despite much skepticism, cases of denunciation are very rare when appointing an ombudsman. Nevertheless, at the beginning of the discussion, the ombudsman will inform the whistleblower that misuse of the whistleblowing system will not be tolerated and that the ombudsman is obliged to pass on information about the whistleblower to the company in the event of deliberate, i.e. conscious, misuse of the system. In all cases, employees who are found to be deliberately misusing the whistleblowing system will face disciplinary action.

The ombudsman ensures compliance with the statutory retention obligations and data protection regulations. The personal data collected is limited to information on the identity of the whistleblower and the individual(s) concerned. The company’s data protection officer regularly checks that the whistleblowing system complies with data protection requirements.

No. All parties are initially presumed innocent. Every whistleblowing complaint is investigated while taking into account the relevant laws and internal rules, and the wishes of all parties concerned. Any remedial actions will only be decided upon completion of the investigation.

As long as the information was provided with good intent and you did not intentionally provide incorrect information, you need not fear any consequences as a whistleblower.

No, use of the ombudsman is voluntary. It has been set up as an additional point of contact in order to minimize any possible reluctance to submit reports.

Yes. It is always possible to visit the ombudsman in person for a confidential conversation.

Yes.

Yes, travel expenses will be reimbursed by the company. This will be handled by the ombudsman to ensure that, if necessary, anonymity can be maintained.

Yes. The ombudsman will share as much information about its findings with the whistleblower as is legally permitted, at the latest after the completion of the investigation.

No. If the ombudsman is called as a witness in criminal, civil or other proceedings, it will only disclose the names of any whistleblowers who have sought its advice if it receives express permission from both the company and the whistleblowers.

Yes. Initial contact with the ombudsman is fully confidential. The ombudsman informs whistleblowers about their rights at the beginning of the discussion. It is only at the end of the discussion that the whistleblower decides whether and in what form the information can be passed onto the company for the purposes of an investigation or internal enquiry.

The ombudsman can also be contacted by whistleblowers who have themselves committed an offense. The ombudsman can provide these whistleblowers with information about their rights. Voluntarily disclosing offenses can also have a positive impact on the company’s decision whether to continue the existing employment relationship and may have a mitigating effect in any judicial proceedings that follow.

No. Only in strictly limited and exceptional cases regarding truly serious crimes is it compulsory for everyone to pass on information relating to a criminal offense to a public prosecutor.

In this case, the ombudsman may contact the company’s management team and/or Compliance department directly.

This varies for each individual case. Some tip-offs can be fully investigated within a matter of hours. However, more extensive investigations can take several weeks to complete.