INTERNAL REPORTING CHANNEL

HW-INOX GmbH has established an internal reporting channel in accordance with the German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG). The internal reporting channel is intended for the confidential receipt and handling of reports on potential legal violations that fall within the material scope of application of Section 2 HinSchG.

Reporting Channels

Reports may be submitted via the following internal reporting channels:

In writing
by email to: hinweisgeber@hw-inox.de

Verbally
in a personal meeting at the request of the reporting person.
The appointment for the personal meeting is arranged by email via the internal reporting channel. The meeting will be made available within a reasonable period of time.

Anonymous reporting is currently not actively offered. Should anonymous reports nevertheless be received, they will be reviewed and handled in accordance with the applicable legal requirements.

Internal Reporting Channel

Reports are received and processed by the internal reporting channel designated for this purpose at HW-INOX GmbH. The internal reporting channel operates independently and free from instructions in accordance with Sections 14 and 15 HinSchG. It ensures the confidentiality of the identity of the reporting person as well as of the persons named in the report.

Procedure and Time Limits

Reports are handled in accordance with the statutory requirements of the German Whistleblower Protection Act:

• Receipt of a report is confirmed to the reporting person within seven (7) days, provided that contact details are available.
• Feedback on any planned or taken follow-up measures is provided no later than three (3) months after confirmation of receipt.
• Possible follow-up measures may include internal reviews, involvement of competent internal departments or, where necessary, disclosure to competent authorities.
  
  

Protection of Reporting Persons and Responsible Use

Reporting persons who submit reports in good faith are protected against disadvantages or retaliatory measures in accordance with Sections 33 et seq. HinSchG.

Knowingly false reports or reports made in a clearly abusive manner are not protected under the German Whistleblower Protection Act and may result in legal consequences.

External Reporting Channels

Irrespective of the use of the internal reporting channel, reports may also be submitted to external reporting channels. The competent external reporting authority at federal level is, in particular, the German Federal Office of Justice (Bundesamt für Justiz). Depending on the subject matter, additional external reporting authorities at federal or state level may also be competent.

Data Protection

Personal data processed in connection with reports submitted via the internal reporting channel are processed exclusively for the purpose of fulfilling statutory obligations under the German Whistleblower Protection Act. Processing is based on Article 6(1)(c) GDPR in conjunction with the HinSchG. Data are stored only for as long as required in accordance with Section 11 HinSchG. The rights of data subjects apply subject to the statutory limitations set out in the HinSchG.