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Anonymous reporting system

Complying with the law is important to us; which is why we systematically care for the task of adhering to both legal and internal regulations in our company, i.e. with so-called compliance. At the same time, we are aware that even the best compliance management cannot prevent individual breaches of rules. This, however, does not mean that we will accept such violations. Rather, we want to clarify any potential violations as much as possible, put a stop to them and learn from them for the future. This is the only way to improve our compliance management and reduce the likelihood of further compliance violations in the future.

We, therefore, support the submission of information on such compliance violations. Nonetheless, many whistleblowers fear retaliation if they point out wrongdoings. For this reason, we have commissioned Grant Thornton AG Wirtschaftsprüfungsgesellschaft, to undertake receiving such information in the strictest confidence and follow up on it objectively with the requisite professional expertise. In parallel, it is prohibited in any way to sanction whistleblower reports made in good faith. Whistleblowers who act in good faith cannot be disadvantaged or subjected to retaliation in any way.

   I. Reporting channels for whistleblowers

On the following page, you can access Grant Thornton’s online-based whistleblower system.

Link to whistleblower system

This system offers whistleblowers the opportunity to confidentially report information on compliance violations, including anonymously if desired. At the same time, the whistleblower system opens the possibility of communication between the whistleblower and Grant Thornton, while guaranteeing the anonymity of the whistleblower.

This whistleblowing system does not utilize robots with automated response settings. Rather, each information is evaluated by qualified specialists and advised by a team of experts. Grant Thornton is committed to the objective and fair investigation of allegations of compliance violations. In addition, every whistleblower is regularly informed – as far as the processing of the submitted report permits – about the progress made in clarifying the facts he or she has reported.

   II. Misuse of the whistleblower system

On the other hand, misuse of the whistleblower system will not be tolerated. We therefore point out that deliberately making untrue allegations about third parties may constitute a criminal offence.

   III. Data protection

We are committed to data protection; this includes ensuring all data subject rights. These rights include the rights of the person against whom the whistleblower alleges a compliance violation (data subject). This includes the right of the data subject to be informed of all personal data of the data subject processed in connection with the whistleblowing. As a rule, the interest of the data subject in receiving information about these data will be secondary until the investigation into the received tip-off has been completed. After the investigation has been completed however, the request for information usually must be complied with. We therefore recommend all whistleblowers to take this circumstance into account when submitting a whistleblowing request, especially if they wish to remain anonymous.

For further information on data protection, please refer to the data protection statement on this website.

   IV. Freedom from seizure

Finally, we would like to point out that Grant Thornton is obliged to maintain confidentiality with regard to information received via the whistleblower system or in any other way; however, this information is generally not exempt from seizure, i.e. investigative or other authorities can seize this information and thus access it upon a corresponding court order.

   V. Further reporting possibilities

Independent of the whistleblower system, our employees still have the option of contacting their supervisor with information at any time.

In addition, the employee is free to choose an external reporting system when submitting his or her report.

For this purpose, the employee can contact the Federal Office of Justice and submit his/her report there under the following link:

BfJ – Hinweisgeberstelle (bundesjustizamt.de)

In addition, the employee can contact the following institutions directly in the case of relevant facts:

European Anti-Fraud Office: Meldung von Betrugsfällen (europa.eu)

European Maritime Safety Agency

European Aviation Safety Agency: Confidential Safety Reporting | EASA (europa.eu)

European Securities and Markets Authority