Compliance – Whistleblowers

We have introduced a system for reporting violations. (Reporting Office)

You have the option of submitting your report via our Reporting Office. You can decide whether to provide contact details or not, and whether you wish to receive feedback. If you request feedback and provide your contact details, you will receive confirmation of receipt of your report via the specified communication channel within 7 days.

You will also receive information within 3 months about how your report was handled, including any measures taken.

Your report will be sent directly to our external Ombudsman (datenschutz nord GmbH, Dominik Bleckmann, fully qualified lawyer), who will treat it confidentially and, after an initial review, forward it to our internal office for further action.

Your reports can be made as follows:

• In person after making an appointment
• By sending a written report by post
• By telephone
• Electronically by email

datenschutz nord GmbH, Konsul-Smidt-Str. 88, D-28217 Bremen

Telephone: +49 421 6966 32 349
Email address: [email protected]

You have the opportunity to submit reports on legal violations or abusive behaviour, in particular in the following areas:

• Violations subject to criminal penalties

• Violations of regulations for the protection of life, limb or health and any rights of employees or their representative bodies that are subject to fines
• Public procurement
• Financial services, financial products and financial markets as well as the prevention of money laundering and terrorist financing
• Product safety and conformity
• Road safety
• Environmental protection
  • Food safety
  • Animal health and public health
  • Consumer protection
  • Protection of privacy and personal data and security of network and information systems
  • Violations of the financial interests of the Union within the meaning of Article 325 TFEU and as further defined in the relevant Union measures
  • Violations of internal market rules within the meaning of Article 26 (2) TFEU, including infringements of Union rules on competition and state aid, as well as infringements of internal market rules in relation to acts contrary to corporate tax rules or in relation to agreements aimed at obtaining a tax advantage contrary to the object or purpose of the applicable corporate tax law.

This list is not exhaustive. You can also report violations in other areas. The exact scope of application can be found in Section 2 of the German Trade Secrets Act (GeschGehG).

Scope of application of the Reporting Office pursuant to Section 2 of the German Whistleblower Protection Act (HinSchG)

The Reporting Office is responsible for receiving reports on the following areas:

• Violations subject to criminal penalties
• Violations subject to fines, insofar as the violated provision serves the protection of life, body or health or the protection of the rights of employees or their representatives.
• Other violations of federal and state laws as well as directly applicable legal acts of the European Union and the European Atomic Energy Community
• for combatting money laundering and terrorist financing, including in particular the Money Laundering Act and Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information on transfers of funds and repealing Regulation (EU) No 1781/2006 (OJ L 141, 5.6.2015, p. 1), as amended by Regulation (EU) 2019/2175 (OJ L 334, 27.12.2019, p. 1), in each case as amended
• with requirements for product safety and conformity
• with requirements for road safety, including road infrastructure safety management, safety requirements in road tunnels and approval for the profession of road haulage operator or passenger road transport operator (bus company)
• with requirements for ensuring railway operational safety
• with requirements for safety in maritime transport concerning EU regulations on the recognition of ship inspection and survey organizations, liability and insurance of carriers in the carriage of passengers at sea, the approval of ship equipment, maritime safety investigations, seafarer training, the registration of persons on passenger ships in maritime transport, as well as EU regulations and procedural rules for the safe loading and unloading of bulk carriers
• with requirements for civil aviation safety in terms of averting dangers to operational and technical safety and in terms of air traffic control
• with requirements for the safe transport of dangerous goods on the road, by rail and by inland waterway
• with requirements for environmental protection
• with requirements for radiation protection and nuclear safety
• for promoting the use of energy from renewable sources and energy efficiency
• for food and feed safety, organic production and labelling of organic products, the protection of geographical indications for agricultural products and food, including wine, flavoured wine products and spirits as well as guaranteed traditional specialities, the placing on the market and use of plant protection products as well as animal health and animal welfare, insofar as they concern the protection of farm animals, the protection of animals at the time of slaughter, the keeping of wild animals in zoos, the protection of animals used for scientific purposes and the transport of animals and related operations
• for standards of quality and safety of organs and substances of human origin, medicinal products for human and veterinary use, medical devices and cross-border patient care
• for the manufacture, presentation and sale of tobacco products and related products

• for the regulation of consumer rights and consumer protection in connection with contracts between entrepreneurs and consumers as well as for the protection of consumers in the field of payment accounts and financial services, price information and unfair commercial practices
• for the protection of privacy in electronic communication, the protection of the confidentiality of communication, the protection of personal data in the area of electronic communication, the protection of the privacy of end-users’ terminals and information stored in these terminals, protection against unreasonable harassment by advertising through telephone calls, automatic calling machines, fax machines or electronic mail as well as caller ID and suppression and inclusion in subscriber directories
• for the protection of personal data in the scope of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1; L 314, 22.11.2016, p. 72; L 127, 23.5.2018, p. 2; L 74, 4.3.2021, p. 35) according to Article 2 thereof
• for security in information technology within the meaning of Section 2 (2) of the BSI Act by providers of digital services within the meaning of Section 2 (12) of the BSI Act
• for the regulation of the rights of shareholders of public limited companies
• for the statutory audit of public interest entities in accordance with Section 316a sentence 2 of the German Commercial Code
• for accounting, including the accounting of companies that are capital market-oriented within the meaning of Section 264d of the Commercial Code, of credit institutions within the meaning of Section 340 (1) of the Commercial Code, financial services institutions within the meaning of Section 340 (4) sentence 1 of the Commercial Code, securities institutions within the meaning of Section 340 (4a) sentence 1 of the Commercial Code, institutions within the meaning of Section 340 (5) sentence 1 of the Commercial Code, insurance undertakings within the meaning of Section 341 (1) of the Commercial Code and pension funds within the meaning of Section 341 (4) sentence 1 of the Commercial Code
• Violations of federally and uniformly applicable regulations for contracting authorities concerning the procedure for the award of public contracts and concessions and concerning legal protection in these procedures from the time the relevant EU thresholds are reached
• Violations covered by Section 4d (1) sentence 1 of the Financial Services Supervision Act (FinDAG), unless otherwise provided for in Section 4 (1) sentence 1
• Violations of legal provisions applicable to corporations and commercial partnerships
• Violations in the form of agreements aimed at improperly obtaining a tax advantage contrary to the object or purpose of the tax law applicable to corporations and commercial partnerships
• Violations of Articles 101 and 102 of the Treaty on the Functioning of the European Union as well as violations of the legal provisions referred to in Section 81 (2) number 1, 2 letter a and number 5 as well as paragraph 3 of the Act against Restraints of Competition
• Violations of the provisions of Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828 (Digital Markets Act) (OJ L 265, 12.10.2022, p. 1)
• Statements by civil servants that constitute a violation of the duty of loyalty to the constitution
• Violations against the protection of the financial interests of the European Union as defined in Article 325 of the Treaty on the Functioning of the European Union
• Violations of internal market regulations as defined in Article 26 (2) of the Treaty on the Functioning of the European Union, including European Union regulations on competition and state aid which extend beyond paragraph 1 (8).