Whistleblower system


"We measure the success of our company not only by economic results, but also by principles based on set values. We act responsibly and correctly, comply with the law and international agreements, and exemplify this attitude every day. The principles of our corporate governance guide every employee in the company. Groz-Beckert has shaped this attitude since the company was founded in 1852 – all over the world and each and every day."

(Excerpt from the Groz-Beckert Code of Conduct)


Groz-Beckert does not tolerate violations of the law of any kind (be it corruption, fraud, theft or illegal agreements), discrimination or violations of ordinances or internal regulations. In order to live up to this claim and to prevent damage to our image and sanctions, we also need you to: Help us prevent or resolve grievances. Work with us to help prevent damage to Groz-Beckert and its employees. Report your suspicion of possible violations of laws, regulations, our Code of Conduct or internal regulations.

You can report such violations via various communication channels shown below. All messages are carefully checked. If necessary, corrective measures are initiated and measures are taken to further improve Groz-Beckert’s Compliance Management System.

We pledge not to take any measures to identify anonymous whistleblowers who do not misuse our whistleblowing system in an illegal manner. Discrimination against whistleblowers will not be tolerated at Groz-Beckert. Persons affected by whistleblowing are presumed innocent until an alleged violation is proven. Your report will be followed up with absolute confidentiality.

Groz-Beckert has set up various reporting channels to give you the greatest possible flexibility and simplify reporting:

You can send your report

by post;

by e-mail to the address specifically set up for this purpose moc.trekceb-zorg@su.llet,

Via the digital whistleblower system "tell us",

using the telephone hotline specially set up for this purpose (direct and as voice message) 5053 01 1347 94+,

or in combination with the aforementioned reporting channels.

A personal meeting is also possible on request.

Groz-Beckert has implemented a Compliance Management System, where the Legal and Insurance department has taken on the role of Central Compliance. We therefore ask you to direct reports by post to them (see "Contacts" for the address). The telephone hotline and the e-mail address moc.trekceb-zorg@su.llet are received directly by the Central Compliance Function.

Even though the Central Compliance Function will handle reports received via the aforementioned channels in the strictest confidence, your anonymity cannot be fully guaranteed and there is no possibility of queries in the case of anonymous reports sent by post.

In order to effectively protect you as a whistleblower, we also offer you our digital whistleblower system "tell us" as a secure communication platform for submitting anonymous reports.

Yes, Groz-Beckert also offers you the option of submitting reports completely anonymously via its digital whistleblower system "tell us" (link see below).

If you voluntarily provide personal data, the data you provide about yourself will only be used for investigating the report you have made and will be stored for as long as is necessary to clarify the compliance notice and its final processing, including the correction of any identified deficits and the processing of any associated legal proceedings. After this time, your data will only be retained if this is required due to legal, official or contractual retention obligations or is permitted by law.

Irrespective of whether you submit your report anonymously or provide us with personal data, the "4 Ws – Who? What? When? Where?" are essential for a successful investigation:

WHO do you think has committed a violation?

WHAT specifically happened (in the "tell us" whistleblower system, we have prepared categories for you here for better classification, which you can use to categorize the violation. For us, the basis of the investigation is a description of the matter that is as detailed as possible)?

WHEN did the violation you reported occur?

WHERE did the violation you reported take place?

The more detailed your answer to these questions in the report, the more successful our investigations are likely to be.

After receiving your report (which we will confirm within 7 days), Groz-Beckert’s Central Compliance Function will assess whether an in-depth investigation is required. An investigation can be performed by in-house or third-party investigation specialists:

The Central Compliance Function is not permitted to conduct the internal investigation. Depending on the content of your report, the Central Compliance Function will determine whether in-house departments (e.g. the relevant management, which is also tasked with rectifying any shortcomings identified in the course of processing the report) are involved, while strictly maintaining confidentiality. If your report concerns an affiliated company, the responsible persons in these companies will be notified, unless you explicitly wish not to involve them. In addition, the Central Compliance Function decides on the involvement of external specialists.

External specialists involved by us (such as lawyers, auditors or forensic experts who investigate the information you provide on behalf of Groz-Beckert) have an obligation to us either by law or contract to keep the information you provide confidential.

In the course of internal or external investigations, persons may be informed and heard about whom a report concerning indications of a compliance violation has been received. Where relevant or required by law, these persons will be given the opportunity to comment on the report during the course of the investigation.

Groz-Beckert may also be legally obliged to provide information on compliance violations to certain government agencies, in particular government investigative authorities or courts. We cannot withhold the information you have provided in the event of disclosure and surrender obligations or in the event of confiscation.

The results of the investigation are then evaluated by the Central Compliance Function. In the event of any misconduct being identified, the Central Compliance Function will then recommend appropriate sanctions to the responsible management.

As a whistleblower, you will receive information about the result of the investigation of the reported violation and the measures taken in response within an appropriate timeframe, at the latest within 3 months after acknowledgement of receipt of your report. The obligation to provide feedback also applies if no result is yet available in the case of longer investigations. In this case, the feedback is limited to information on the current status of the investigations.

Upon completion of the review, your report will be documented in compliance with the confidentiality requirement and deleted two years after the conclusion of the procedure.

Before submitting any report, please check whether there is sufficient reason to assume that the information on which the report is based corresponds to the truth.

Therefore, only provide us with information that you believe to be correct to the best of your knowledge. If you knowingly give false or misleading information, you will face consequences. Knowingly spreading false information is punishable by law in many countries. In general, please do not provide us with any information if this is punishable under the law of your country.

In this context, we would like to point out that people affected by your information or government agencies may have rights to information or seizure. This may be the case, in particular, if the person concerned claims that the information provided against him or her is knowingly or negligently untrue and files a criminal complaint against this.

Yes, the Groz-Beckert whistleblower system does not prevent you from submitting your report to an external reporting channel. Depending on the report, this could be, for example, the relevant authorities (in Germany, for example, public prosecutors' offices, federal institutions). In addition, a central external reporting office is to be set up at the “Bundesamt für Justiz (BfJ)” in Germany, and the federal states have the option of setting up their own external reporting channels for reports that affect the respective state and local governments.


Go to the digital whistleblower system "tell us"

With the "tell us" whistleblower system, Groz-Beckert offers you the option of addressing reports anonymously or voluntarily using personal information.

Groz-Beckert uses "whistleOps by 2B Advice" for this purpose

It is a platform that includes a ticket system to manage the case, is GDPR compliant and meets all requirements of the Whistleblower Policy.

The data is stored on servers in a high-security data center in Germany. Personal data entered into the whistleblower system is stored in a database operated by 2B Advice. All data is encrypted, password-protected and stored in a secure location, so that access to the content of the electronically stored data is restricted to a narrow group of authorized persons at Groz-Beckert. 2B Advice cannot view the content of the data stored electronically in the database. If you do not enter any personal information yourself, the whistleblower system automatically protects your anonymity via a certified procedure, which is backed up by extensive technical and organizational measures.

The "tell us" whistleblower system will always address your ticket exclusively to the Central Compliance Function of Groz-Beckert KG.


TO THE "tell us" WHISTLEBLOWER SYSTEM

For countries with an obligation to maintain a system in the national language and to report within the country, Groz-Beckert also offers "tell us" in a form where the system is available in the national language and the ticket is processed by the respective Compliance Responsible Person in the respective country. In this case, however, you, as the whistleblower, also have the option of contacting the Groz-Beckert Central Compliance Function directly via the above system.


Country-specific systems:

Person responsible for compliance:
Mrs. Mónica Gonçalves
Proteção de Dados e Gestão do Meio Ambiente, Saúde e Segurança Ocupacional
Data Protection and Environment, Health and Safety Management

moc.trekceb-zorg@sevlacnog.acinom
16 52 517 22 153+


TO THE "tell us" WHISTLEBLOWER SYSTEM

 


Contact

Dr. Christian H. Müller
Head of Legal and Insurance/General Counsel
(Central Compliance Function as part of the Compliance Management System at Groz-Beckert)

Groz-Beckert KG
Parkweg 2
72458 Albstadt


moc.trekceb-zorg@su.llet
5053 01 1347 94+