Dorint policy on dealing with internal whistleblowers
Employees in companies (employees, interns, trainees, temporary workers, etc.) are often the first to notice grievances and can use their information to ensure that legal violations are uncovered, investigated, prosecuted and stopped. Whistleblowers assume responsibility for society and therefore deserve protection from the discrimination they may face because of their report and which may deter them from doing so. We provide internal and external whistleblowers with various reporting channels. "Dorint Tell Us" is a secure reporting channel through which our employees in particular can confidentially report possible violations. Incoming reports are stored on an external server and prioritized by the ombudsperson. The whistleblower can be confident that their identity is protected as far as possible, as is the identity of the persons named in a report.
The ombudsperson confirms receipt of a report to the whistleblower within 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 may take the following follow-up measures in particular:
1. conduct internal investigations at the employment provider or at the respective organizational unit and contact affected persons and work units,
2. refer the whistleblower to other competent bodies,
3. close the proceedings for lack of evidence or for other reasons, or
4. hand over the proceedings for further investigation to a) a work unit responsible for internal investigations at the employer or at the respective organizational unit or b) a competent authority. The ombudsperson shall 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 includes notification of planned and already taken follow-up measures as well as 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 reports of suspected misconduct can be reported to the company's internal neutral body, the Compliance Officer.
Whistleblowers are comprehensively protected against reprisals, provided that the reported information has not been obtained unlawfully. This includes all unjustified disadvantages such as dismissal, denial of promotion, changed assignment of duties, disciplinary measures, discrimination or harassment suffered by a whistleblower as a result of a report or disclosure.
In this context, it should be noted that a whistleblower is liable to pay compensation for damages resulting from the intentional or grossly negligent reporting or disclosure of inaccurate information. This means that whistleblowers who knowingly provide false or misleading information must expect consequences. Knowingly disseminating false information may be punishable by law. Information provided to the best of our knowledge will not have any negative consequences on our part.