HAVER & BOECKER Whistleblower system

HAVER & BOECKER is committed to responsible and sustainable corporate management. Integrity and lawful behavior are of the highest priority. Therefore, HAVER & BOECKER is interested in being informed early on about serious violations of laws or internal guidelines in the company.

1. Guarantee of confidentiality

It is a matter of course for HAVER & BOECKER that information from the whistleblower system is treated as strictly confidential. Confidentiality is ensured, among other things, by implementing information security measures within data processing.

The tips are accepted by a lawyer who is subject to attorney-client confidentiality.

2. Guarantee that no retaliatory measures will be taken

HAVER & BOECKER does not see the tips as an attack, but as a tip that helps HAVER & BOECKER to remedy conditions/situations and thus achieve an improvement. HAVER & BOECKER attaches great importance to protecting whistleblowers from any disadvantages due to their report and guarantees that no retaliatory measures will be taken. We also ask that you use the whistleblower system responsibly, as false accusations can have serious consequences for those affected.
 

Knowingly making false reports or other misuse of the system is not permitted and can have labor and criminal law consequences.

3. Misconduct by H&B employees

It is about preventing damage to the company. Violations of rules damage the company, misconduct by individuals comes at the expense of the entire workforce. Integrity and behavior that complies with the law and rules (compliance) form the basis for HAVER & BOECKER's good reputation and for the trust of our customers and business partners. At the same time, compliance has a significant impact on the well-being of employees in the company and on the company's sustainable economic success. In order to achieve this and to be able to recognize violations of laws and rules in a timely manner, stop them immediately and, if necessary, punish them, the help of every individual is required. The prompt and objective clarification of suspicious reports by our company is essential for this.

4. Misconduct by suppliers

For HAVER & BOECKER, sustainability means pursuing economic, social and ecological goals equally and simultaneously. We want to live up to this responsibility on a global level and also in our business relationships. We implement various measures to ensure that our suppliers comply with our sustainability requirements. Should violations nevertheless occur, we rely on being informed of them.

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

Violations of applicable law
Human rights or environmental risks or violations in the company's own business area and in the supply chain (§§ 8 and 9 of the LkSG)
Violations of Article 15 GDPR (right of the data subject to information)

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

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

1. Report via the whistleblower system on the HAVER & BOECKER website: www.haverboecker.com/de/unternehmen/hinweisgebersystem

You can also find further links on the subsidiaries' websites that lead to the HAVER & BOECKER link.

The website is designed in such a way that it is possible to provide information anonymously, without any traceability. The whistleblower system operates in a protected channel that was specially set up by IT. Whistleblowers who do not want to send their information to HAVER & BOECKER via the Internet can send their information to HAVER & BOECKER by post.

2. All requests from those affected that relate to the GDPR will be forwarded to the data protection officer as quickly as possible so that he can determine the legality of the request and initiate the necessary further steps.

3. When processing reports, our legal advice is responsible in particular for the following (Article 12 paragraph (4) Directive (EU) 2019/1937):

• Transmitting information about the reporting procedures to any interested parties
• Receiving reports and documenting the information in the form AB-F-NM-01 "Whistleblower system reporting form" (Article 18, Directive (EU) 2019/1937)
• Confirming receipt of a report by the whistleblower within a period of seven days (Article 9 letter b, Directive (EU) 2019/1937)).
• Forwarding to the relevant responsible persons and management
• Initiating and implementing measures
• Checking the effectiveness of the measures
• Maintaining contact with the whistleblower to provide feedback and, if necessary, requesting further information. The feedback must be provided within a reasonable timeframe, namely within a maximum of three months from the confirmation of receipt of the report or - if receipt was not confirmed to the whistleblower - three months after the expiry of the period of seven days following receipt of the report (Article 9(f), Directive (EU) 2019/1937).
• Completion of the whistleblower report

Form: AB-F-NM 01 "Whistleblower system reporting form"

Any changes to this Procedure must also be made on the website.