HAVER & BOECKER Whistleblower system

HAVER & BOECKER is committed to responsible and sustainable corporate management. Integrity and lawful behaviour have the highest priority. HAVER & BOECKER is thus interested in being informed at an early stage about serious violations of laws or in-house guidelines within the company.

1. Misconduct by H&B staff

The objective is to avert damage to the company. Breaches of rules are detrimental to the company; misconduct by individuals is at the expense of the entire workforce. Integrity and compliance with laws and regulations represent the basis for HAVER & BOECKER's good reputation and for the trust placed in us by our customers and business partners. At the same time, compliance has a significant impact on the well-being of the employees in the company and on the sustainable economic success of the company success. The cooperation of every individual is required in order to achieve this aim, to be able to identify infringements of the law and rules in good time and to put a stop to violations promptly and, if necessary, to impose penalties. The rapid and objective clarification of reports of suspicious activity by our company is therefore indispensable.

2. Supplier misconduct

For HAVER & BOECKER, sustainability means striving to achieve economic, social and ecological goals with equal priority and contemporaneously. We want to uphold this responsibility both on a global level as well as in our business relationships. We implement various measures to ensure that our suppliers comply with our sustainability requirements. Should infringements nevertheless occur, we rely on being notified of these violations.

Appropriate complaint procedures are a core element of the due diligence obligations, which is why this whistleblower reporting system provides opportunities for reporting in particular the following to HAVER & BOECKER:

1. Breaches of the applicable law
2. Human rights violations or environmental risks or violations in the company's own fields of business and in the supply chain (Sections 8 and 9 of the German Supply Chain Due Diligence Act (LkSG)).
3. Infringements of Article 15 of the GDPR (Right of access by the data subject)

These procedural instructions apply to HAVER & BOECKER OHG and its subsidiaries.

Our legal counsel  (legal@haverboecker.com) and the department/area concerned

1. Reporting via the whistleblower system on the HAVER & BOECKER website.
2. All enquiries from data subjects relating to GDPR will be forwarded to the data protection officer without delay so that they can identify the legitimacy of the request and determine and initiate the necessary further steps to be taken.
3. Our legal counsel is responsible in particular for the following when processing reported incidents (Article 12(4) Directive (EU) 2019/1937):
   1. providing any interested persons with information on the procedures for reporting;
   2. receiving reports and documentation of the information in form AB-F-NM-01 "Whistleblower system reporting form" (Article 18, Directive (EU) 2019/1937);
   3. sending acknowledgement of receipt of a report to the whistleblower within a period of seven days (Article 9(b), Directive (EU) 2019/1937);
   4. forwarding of reports to the relevant persons in charge and the management;
   5. initiating and implementing measures;
   6. monitoring the effectiveness of the measures taken;
   7. maintaining contact with the whistleblower for the purpose of providing feedback and requesting further information if necessary. The feedback must be provided within a reasonable timeframe, not exceeding three months from the acknowledgement of receipt or, if no acknowledgement was sent to the reporting person, three months from the expiry of the seven-day period after the report was made (Article 9(f), Directive (EU) 2019/1937).
   8.  Finalisation of the whistleblower report