1. GUIDELINE
WHISTLEBLOWING SYSTEM
Sustainable business practices form the basis for future prospects for the environment, society and the economy, and also for every individual employee or business partner of the DEMA Electronic Group.
Cornerstones of our corporate culture are the allocation of central requirements and their independent implementation and management within the subsidiaries, as well as a shared understanding of values and risk minimisation for sustainable corporate development.
The whistleblowing system with legal expertise provided by Ratisbona Compliance (“RC-Whistle”) creates additional trust and security in reporting misconduct through an accessible, clearly defined structure and an initial legal assessment, thereby safeguarding the sustainable success of the DEMA Electronic Group and preventing damage.
2. SCOPE OF APPLICATION
2.1. This policy describes the procedure for reporting confirmed or suspected misconduct or wrongdoing.
2.2. It applies to all employees (including temporary agency workers), customers, suppliers and all those who have an interest in the well-being of the company.
3. KNOWLEDGE OR REASONABLE SUSPICION OF MISCONDUCT
3.1. We would like to encourage anyone to report if they have knowledge of, or a reasonable suspicion regarding, significant misconduct/wrongdoing (breach of law or unethical behaviour contrary to our Code of Conduct).
3.2. We encourage everyone to report such matters via the known and established reporting channels. These are:
a. Trusted person
b. Human Resources
c. Management
d. Compliance department
3.3. If none of these reporting channels are suitable for your report, the whistleblowing system with legal expertise provided by Ratisbona Compliance is available to you as a reporting channel. The Ratisbona Compliance whistleblowing system is operated by an independent third party.
3.4. Through the whistleblowing system with legal expertise provided by Ratisbona Compliance, reports are submitted directly to Ratisbona Compliance. Reports may be made digitally via Ratisbona Compliance’s reporting platform, by telephone or in person.
4. DELIBERATE FALSE REPORTS
Deliberate false reports are regarded as a violation of the Code of Conduct and will be handled accordingly. They may result in disciplinary measures and/or criminal prosecution.
5. ALLOCATION OF RESPONSIBILITIES
5.1. Through the Ratisbona Compliance whistleblowing system, anonymous communication with the whistleblower is possible and, if necessary, ensured. After receipt of a report alleging misconduct or fraudulent behaviour, the facts will be subject to an initial review based on the information provided.
5.2. Ratisbona Compliance assumes responsibility for reviewing and processing incoming reports within the applicable time limits.
5.3. Follow-up questions to the whistleblower for further assessment of the facts, while maintaining anonymity, are possible.
5.4. Based on this initial review, the further course of action for dealing with the matter is determined. Depending on the severity of the allegation, the group of persons concerned and the relevant area of law, the report is forwarded to the responsible body of the respective affected investment/participation or participation group. External experts may be consulted in the further review of the misconduct. There may be an obligation to report to authorities if there is sufficient suspicion of a criminal offence. Ratisbona Compliance ensures that all reported cases are investigated and concluded with sufficient documentation.
5.5. DEMA Electronic expects managers and supervisors at all hierarchical levels to take such reports seriously, to treat them strictly confidentially and to clarify them promptly with the applicable requirements and necessary measures in order to eliminate the misconduct.
6. NO FURTHER PURSUIT
OF A REPORT
Ratisbona Compliance may conclude that a report will not be pursued further, for example if:
a. only insufficient information is available for an appropriate investigation and there is also no possibility of obtaining further information
b. the report is demonstrably a false report.
7. REPORTING
Reporting is carried out by the Legal Department of Ratisbona Compliance. Reporting is detailed for cases investigated by Ratisbona Compliance.
8. PROTECTION AND RIGHTS OF THE
REPORTING PERSON
8.1. The identity of all reporting persons is treated with absolute confidentiality. Under no circumstances will Ratisbona Compliance disclose voice messages, IP addresses and/or telephone numbers unless “8.3.” applies.
8.2. No one who submits a report has to fear negative consequences as a result. However, reporting persons (as whistleblowers) also do not enjoy protection in the event of misconduct.
8.3. In the following cases, protection of the reporting person is not guaranteed:
a. Upon request, for example by law enforcement authorities, Ratisbona Compliance is obliged to provide voice messages, IP addresses and/or telephone numbers.
b. cases in which it has been determined that reports were made deliberately false, contrary to better knowledge and/or in bad faith (“mala fide”);
c. or if the report itself must be classified as a criminal offence or a violation of the Code of Conduct (e.g. slander or threats).
8.4. If the reporting person does not agree with the outcome of the investigation, they have the opportunity to communicate this again via the whistleblowing system with legal expertise provided by Ratisbona Compliance.
9. PROTECTION AND RIGHTS
OF ACCUSED PERSONS
If investigations are initiated as a result of a report, DEMA Electronic will
9.1. inform the persons concerned no later than within 30 working days. This phase may also be extended after weighing the case-specific situation, for example if there is a risk that evidence will be destroyed or the initiated investigations will otherwise be obstructed.
9.2. Persons concerned have the right to complain about investigations directed against them. For this purpose, persons concerned should contact:
a. their supervisor or managing director
b. Ratisbona Compliance (contact information can be found at the end of this policy).
10. DATA PROTECTION
Ratisbona Compliance will treat all information strictly confidentially. Protection of data of both reporting persons and persons concerned is assured within the legal framework. Information is made accessible on a restricted basis with regard to both content and the group of persons (so-called “need-to-know basis”). This policy entails the processing and storage of personal data. This is carried out exclusively in accordance with data protection regulations.
11. PROCESSING PROCEDURE
OF RATISBONA COMPLIANCE
12. DIGITAL REPORTING PLATFORM
1. ELECTRONIC REPORT
Before submitting your report via our system, please read the data protection information for whistleblowers.
By clicking on the link “Submit a report”, which leads to the input form of the whistleblowing system, you confirm that you have taken note of the data protection information.
Alternatively, you can also scan this QR code.
2. TELEPHONE REPORT
Would you like to submit your report by telephone?
You can reach the team of attorney Erich. J. Beer at: +49 941 2060384-2
3. IN-PERSON MEETING
Would you like to submit a report in a personal meeting?
Contact us at:
Ratisbona Compliance GmbH
Trothengasse 5
93047 Regensburg
Germany
+49 941 2060384-1
info@ratisbona-compliance.de