Whistleblower system of the uvex group
"Based on our mission of protecting people, the uvex group is always aware of its responsibility to society and the environment. Group-wide binding standards, such as the Social Standard, but also the Compliance Guidelines and the Code of Conduct, provide us with the corresponding regulations. These describe behaviors and principles on how we and our business partners conduct our actions and decision-making in a legally correct, but also ecologically sustainable and socially responsible manner. Our goal is to deal with each other responsibly and sustainably. For us, this also includes following up on indications of conduct that is not in compliance with the law or our guidelines. We have set up various reporting channels for this purpose."
Susann Schubert, Director Corporate Social Responsibility of the uvex group
Description of the ombudsman service (whistleblower system) of the uvex group
Employees, suppliers, agents and subcontractors may report violations of the uvex group's Social Standard to compliance@uvex.de. These reports can be made confidentially and the identity of the reporter is not disclosed.
Business partners must ensure that subcontractors, suppliers and their own business partners are also informed about this reporting procedure and made aware of its confidential nature.
In addition to the contact option mentioned above, an external ombudsman service has also been established. This can be reached as follows:
Ombudsman service:
Baker Tilly Rechtsanwaltsgesellschaft mbH
Nymphenburger Str. 3b
80335 München
Deutschland
Telefon: +49 89 55066-525
E-Mail: ombudsservice.uvex@bakertilly.de
What does the term “uvex group” used below mean?
Der Begriff „uvex group“ beinhaltet die UVEX WINTER HOLDING GmbH & Co. KG und alle mit ihr verbundenen Unternehmen (§15 AktG).
What does the term “ombudsman service” used below mean?
The term “ombudsman service” refers to the provision of an external and impartial whistleblower system by the uvex group, which operates according to the application principles defined below.
What can be reported?
Any sign of illegal behaviour that has a corporate connection to the uvex group or contravenes internal company guidelines.
This must not, however, include allegations against better judgement
In case of doubt, the ombudspersons are also available to discuss whether an observation falls within the scope of the ombudsman service.
What is the purpose of the ombudsman service?
All authorised persons described below should be able to report behaviour that contravenes the law or does not comply with our “Code of Conduct”, to the responsible persons, without fear of prejudice or any other such repercussions.
By providing the ombudsman service described below, the uvex group is also participating in an external complaints procedure for implementing the requirements of the Due Diligence Act (LkSG). This gives the following authorized persons the opportunity to point out human rights or environmental risks, or to report violations of human or environmental rights, which are associated with the corporate actions of the uvex group or its business partners.
Reports that are not connected to the described purpose may be rejected.
What is the aim of the ombudsman service?
The aim of the ombudsman service is to prevent and resolve contraventions of the law, in particular economic offences (e.g. corruption, antitrust violations, fraud, and embezzlement), in connection with the uvex group, as well as other company-related criminal offences, or violations of the uvex group’s compliance guidelines or standards of conduct. The ombudsman service additionally seeks to prevent the violation of human and environmental rights.
Who is authorized to provide information?
The ombudsman service is available to all current and former employees, including trainees, temporary personnel, and interns, as well as to business partners of the uvex group (hereinafter referred to as “persons authorized to report”).
Can reports be submitted anonymously?
Yes, every person authorized to report has the option of submitting the report anonymously. If the person authorized to report reveals his/her identity, the ombudsperson will treat this identity as confidential at the request of this person.
How are anonymous reports handled?
The two ombudspersons assert that they will not, under any circumstances, reveal the name of the whistleblower to the uvex group, if the whistleblower wishes to remain anonymous. The uvex group has contractually waived any requests for information from the ombudsman service.
Only in cases where the whistleblower expressly permits the ombudsman service to forward the communicated information and to divulge his/her identity to the uvex group will the ombudsman service pass these details on to the authorized contacts of the uvex group.
In the case of anonymous reports, it should be noted that communication with anonymous whistleblowers may be difficult or even impossible if queries arise which serve to resolve the matter. In such instances, the ombudsman service is also unable to provide the anonymous whistleblower any feedback on the handling of his/her case.
How is the confidentiality of the report ensured?
As licensed lawyers, ombudspersons are professionally and legally bound to secrecy. The ombudspersons will only pass on the report or information from the report to third parties (including the uvex group) if the reporting party has explicitly agreed to this.
Are the ombudspersons subject to instructions from third parties?
The ombudspersons are not subject to any form of instruction from third parties, and particularly not from the uvex group, in relation to submitted reports. The ombudspersons are impartial. In particular, they are at liberty to assess the facts and to communicate with the reporting party.
Is there an obligation to release information?
The uvex group expects its employees to take joint responsibility for compliance with legal and internal regulations.
In this respect, the use of the available reporting procedure and reporting of any knowledge of improper conduct in business transactions, of other criminal matters pertaining to the company, or of violations of internal company regulations, is welcomed.
We explicitly wish to point out, however, that the use of this procedure is entirely voluntary, unless legal or contractual notification requirements already exist.
Note: Legal or contractual notification requirements of this nature currently only exist if there is an immediate, substantial risk to safety or health within the company or a flaw is identified in the company's occupational health system, or if there is a risk of considerable personal injury or serious property damage for the company which is still currently avoidable.
Which reporting procedures are available in addition to the ombudsman service?
As an alternative to the option described here of reporting via the ombudsman service, employees of the uvex group can also report compliance-related matters to the Compliance contact published on the intranet. Employees of the uvex group's business partners have the option of reporting compliance-related matters to the e-mail address compliance@uvex.de.
How do I contact the ombudsman service?
The contact details for the ombudsman service are as follows:
Dr. Stefan Meßmer
Partner
Rechtsanwalt
Christine Ostwald
Director
Rechtsanwältin,
Fachanwältin für Arbeitsrecht
Baker Tilly Rechtsanwaltsgesellschaft mbH
Nymphenburger Str. 3b
80335 Munich, Germany
Information can be provided in person, by telephone, in writing, or using electronic media (e-mail, SMS).
Phone: +49 89 55066-525
E-mail: ombudsservice.uvex@bakertilly.de
Availability:
• By phone: Mon-Fri 8:00 am to 18:00 pm (Central European Time)
• Personally: by appointment
• E-mail, SMS: at any time
Information can be provided in German or English. Reports in other languages can be submitted by e-mail. These will be machine-translated. In these instances, an answer will always be provided in English. If serious violations are suspected, a translation agency bound to confidentiality will be called in to enable communication in the language of the reporting party.
How are reports processed within the whistleblower system?
The qualified processing of all reports received by the ombudsperson is carried out in accordance with a standardized procedure by Baker Tilly Rechtsanwaltsgesellschaft mbH.
When information is received by the ombudsperson, a further course of action is always agreed between the ombudsperson and the whistleblower, unless the latter is to remain anonymous.
Following its receipt, the information is subjected to a qualified review, to verify its credibility and plausibility. An initial assessment of the legal position is also conducted, and recommendations for a further course of action are made.
A separate inquiry into the facts of the matter is not carried out.
The whistleblower receives qualified feedback if he/she is known to the ombudsperson.
Will the reporting party incur any costs as a result of using the ombudsman service?
No. The reporting party will not incur any costs as a result of using the ombudsman service.
uvex group Code of Conduct
24.02.2022