Whistleblower.
At Westernacher, we promote a culture of integrity and transparency. Those associated with us in a professional context should feel confident that they can do the right thing. Part of this is being able to raise concerns. If you experience or hear about behaviour that is inconsistent with our corporate culture or codes of conduct, or that may not comply with legal requirements, we want you to report it so that it can be dealt with appropriately.
This concerns the following (potential) offences, among others:
- Unlawful acts and omissions that are punishable by a penalty or fine (criminal offences or administrative offences)
- Human rights and environmental risks and violations of human rights or environmental obligations
- Violations of internal company guidelines
Reporting office & reporting channels:
We have decided to set up a cross-company internal reporting office and have two different reporting channels available for this purpose.
You are free to contact one or both of our confidential counsellors (case managers) anonymously or under a pseudonym. However, even if you contact the reporting office by name, your identity will not be disclosed (without your consent) – neither to third parties nor to colleagues or the management.
The reporting office will process incoming reports in accordance with the dual control principle and the two confidential counsellors (case managers) have the necessary powers to perform the tasks of the internal reporting office and to take follow-up measures independently of instructions.
The persons of trust (case managers) are:
Mathias Vogel
Data Protection Officer of Westernacher Business Management Consulting GmbH
Telephone number: +49 (0) 671 / 20 272 041
Florian Daniel
Legal Counsel & Data Protection Coordinator of Westernacher Solutions GmbH
Telephone number: +49 (0) 30 / 58 58 122 77
E-mail address of the reporting office: whistleblower@westernacher.com
Both trusted persons (case managers) have access to this e-mail inbox.
Please also note the following information:
Protected group of persons
Whistleblowers, including employees, staff, shareholders, employees of suppliers, customers and applicants.
The protected group of persons also includes potential witnesses and other supporting persons, such as colleagues of the person providing the information.
Absolute confidentiality
You can rely on our absolute confidentiality! Under no circumstances do you have to fear any professional consequences or suffer any other disadvantages as a whistleblower if you contact our reporting office.
We have taken technical and organisational measures to ensure that, with the exception of the appointed trusted persons (case managers), no one has access to the protected information and that it is treated with absolute confidentiality. Even the management will not know the identity of the persons belonging to the protected group of people.
Requirements for the degree of suspicion
Information about violations that give rise to reasonable suspicion or knowledge of actual or potential violations and attempts to conceal such violations that are in the professional context and that have already been committed or are likely to be committed.
The requirements for the substantiation of suspicions are low.
Please note, however:
A deliberately false report can have consequences under criminal law.
Legal texts
Whistleblower Protection Act (Germany / Hinweisgeberschutzgesetz):
https://www.gesetze-im-internet.de/hinschg/
Directive (EU) 2019/1937 (“Whistleblower Directive”):
http://data.europa.eu/eli/dir/2019/1937/oj
External reporting office in Germany
Of course, you are also free to contact an external reporting office with your concerns.
The federal government has set up an external reporting office via the Federal Office of Justice (BfJ), which you can reach via the following link:
https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html
