Whistleblower system
Sustainable management is the basis for future prospects for the environment, society and the economy and also for each individual employee or business partner of Maschinenfabrik Herbert Meyer GmbH.
The cornerstones of the Maschinenfabrik Herbert Meyer GmbH culture are the division of central requirements and their independent implementation and controls in the departments as well as a common understanding of values and risk minimization for sustainable corporate development.
The whistleblower system with legal expertise from Ratisbona Compliance GmbH (“RC-Whistle”) creates additional trust and security through a clearly defined structure that is accessible to everyone and a legally sound initial assessment in order to point out grievances and thus secure the sustainable success of Maschinenfabrik Herbert Meyer GmbH and avert damage.
Whistleblowing Directive
Guidelines
Sustainable management is the basis for future prospects for the environment, society and the economy and also for each individual employee or business partner of Maschinenfabrik Herbert Meyer GmbH.
The cornerstones of the Maschinenfabrik Herbert Meyer GmbH cultureare the division of central requirements and their independent implementation and controls in the subsidiaries as well as a common understanding of values and risk minimization for sustainable corporate development.
The whistleblower system with legal expertise from Ratisbona Compliance (“RC-Whistle”) creates additional trust and security through a clearly defined structure that is accessible to everyone, as well as the legally sound initial assessment, to point out grievances and thus secure the sustainable success of Maschinenfabrik Herbert Meyer GmbHand avert damage.
Area of application
- This guideline describes the procedure for reporting confirmed or suspected grievances or misconduct.
- It applies to all employees (including temporary workers), customers, suppliers and all those who have an interest in the well-being of the company.
Knowledge or reasonable suspicion of maladministration
- We encourage any employee who has knowledge or reasonable suspicion of significant abuses (violation of the law or unethical behavior contrary to our Code of Conduct) to report it.
- We encourage each and every employee to report such matters through the known and established reporting channels. These are (by way of example)
- Person of trust
- Human resources
- Works Council
- Management
- Internal suggestion and reporting system
- Compliance area
- If none of these reporting channels are suitable for your message, the RATISBONA COMPLIANCE whistleblower system with legal expertise is available to you as a reporting channel. The RATISBONA COMPLIANCE whistleblower system is operated by an independent third party.
- Messages are sent directly to RATISBONA COMPLIANCE via the whistleblower system with legal expertise from RATISBONA COMPLIANCE. Messages can be submitted digitally via the Ratisbona Compliance reporting platform, by telephone or in person.
Deliberate false reports
Intentional false reports will be considered a violation of the Code of Conduct and treated accordingly. They may lead to disciplinary action and/or prosecution.
Allocation of responsibilities
- RATISBONA COMPLIANCE’s whistleblower system enables anonymous communication with the whistleblower and ensures this if necessary. After receiving a message about alleged misconduct or fraudulent behavior, the facts of the case are subjected to an initial review based on the information contained therein.
- RATISBONA COMPLIANCE is responsible for checking and editing the incoming messages in due time.
- Questions may be put to the whistleblower for further assessment of the facts while maintaining anonymity.
- Based on this initial review, the next steps for dealing with the matter are determined. Depending on the severity of the allegation, the group of people affected and the area of law, the message is transferred to the responsible body of the respective participation or participation group concerned. External experts may be consulted for further examination of the grievance. There may be a duty to report if there is sufficient suspicion of a criminal offense. RATISBONA COMPLIANCE secures that all reported cases are investigated and concluded with sufficient documentation.
- Maschinenfabrik Herbert Meyer GmbH expects managers and supervisors at all hierarchical levels to take such messages seriously, to treat them in strict confidence and to clarify them promptly with the appropriate guidelines and necessary measures in order to eliminate the grievance.
No follow-up of a message
RATISBONA COMPLIANCE may come to the conclusion that a message will not be followed up, for example if
-
- insufficient information is available for an adequate investigation and there is no possibility of obtaining further information
- the message is proven to be a false report.
Reporting
Reporting is carried out by the legal department of RATISBONA COMPLIANCE. Reporting is detailed for the cases investigated by RATISBONA COMPLIANCE.
Protection and rights of the whistleblower
- The identity of all Reporting Parties will be kept absolutely confidential. Ratisbona Compliance will under no circumstances disclose voicemails, IP addresses and/or telephone numbers, unless “8 c” is applicable.
- No one who makes a report will suffer any negative consequences as a result. However, reporting parties (as whistleblowers) also enjoy no protection in the event of misconduct.
- In the following cases, whistleblower protection is not guaranteed:
- i. Upon request, e.g. by law enforcement authorities, Ratisbona Compliance is obliged to provide voice messages, IP addresses and/or telephone numbers.
- ii. Cases where it has been determined that reports were intentionally made falsely or against better judgment and/or in bad faith;
- iii. or where the report itself must be classified as a criminal offense or violation of the Code of Conduct (e.g., defamation or threats).
- If the reporter does not agree with the result of the investigation, he/she again has the possibility to make this known via the whistleblower system with legal expertise of Ratisbona Compliance.
Protection and rights of the accused
- If an investigation is initiated as a result of a message, Maschinenfabrik Herbert Meyer GmbH will inform the persons concerned within 30 working days at the latest. This phase can also be lengthened, taking into account the case-specific situation, e.g. if there is a risk that evidence will be destroyed or the investigation that has been initiated will be otherwise hindered.
- Those affected have the right to complain about investigations directed against them. Those affected should contact:
- Your supervisor or managing director
- The RATISBONA COMPLIANCE contact information can be found at the end of these guidelines.
Data protection
Ratisbona Compliance will treat all information as strictly confidential. The contactor’s data as well as that of the data subject is guaranteed within the legal framework. Information is made available on a limited basis, both in terms of content and the group of people involved (so-called “need-to-know basis”). This guideline requires the treatment and storage of personal data. This is done exclusively in accordance with data protection regulations.
Ratisbona Compliance GmbH
Trothengasse 5
93047 Regensburg
Tel +49 941 2060384-1
E-mail: info@ratisbona-compliance.de
www.ratisbona-compliance.de