We provide internal and external whistleblowers with various reporting channels. "Dorint Tell Us" is a secure reporting channel through which our employees, guests, suppliers and business partners can confidentially report possible violations. Incoming reports are stored on an external server and prioritized by the ombudsperson.
The ombudsperson confirms receipt of a report to the whistleblower after seven days at the latest and checks whether the reported violation is relevant and violates the Code of Conduct. The ombudsperson shall maintain contact with the whistleblower and verify the validity of the report received and, if necessary, request further information from the whistleblower. The ombudsperson then takes appropriate follow-up measures (e.g. referral of the whistleblower to the competent body/authority. Discontinuation of proceedings due to lack of evidence). If internal company support is required to fulfill this task, the ombudsperson is supported by the Compliance Officer and internal investigations are initiated.
The ombudsperson will provide feedback to the whistleblower within three months of confirming receipt of the report or, if receipt has not been confirmed, no later than three months and seven days after receipt of the report. The feedback shall include notification of any follow-up measures planned or already taken and the reasons for these. Feedback may only be provided to the whistleblower to the extent that this does not affect internal inquiries or investigations and the rights of the persons who are the subject of a report or who are named in the report are not impaired.
In addition, possible misconduct can of course also be reported directly, via the Management Board, the Works Council or via managers. In particular, incidents and suspicions can be reported to the company's internal neutral body, the Compliance Officer.
Internal whistleblowers are protected by a special policy that prohibits in any way the sanctioning of reports made in good faith. Accordingly, whistleblowers acting in good faith may not be disadvantaged in any way. Whistleblowers who believe that they or other persons have been retaliated against or that they or other persons have been disadvantaged in any way because of the complaint are requested to inform us of this via one of the reporting channels.
Whistleblowers should only submit complaints or reports if they are convinced of their accuracy. It is hereby pointed out that the whistleblower is obliged to pay compensation for any damage resulting from an intentional or grossly negligent report or disclosure of incorrect information. Knowingly disseminating false information may be a criminal offense and will be punished.
Ombudsperson:
Dr. Charlotte Lauser, lawyer, specialist lawyer for information technology law GDD cert.EU Data Protection Officer Data Protection Auditor DSA-TÜV Dr.-Gerhard-Hanke-Weg 31 85221 Dachau
Phone +49 (0)8131 338582 Fax. +49 8131 511 619 E-Mail: datenschutz(at)lauser-nhk.de
Internal company compliance officer:
Jessica Mersmann, LL.M., Attorney at Law (in-house lawyer), Vice President Legal & Compliance E-Mail: jessica.mersmann(at)honestis.ag