- Criminal offences, particularly acts of corruption, such as fraud, breach of trust, embezzlement, theft, bribery/corruption, etc.
- Other criminal offences (without financial limits in respect of damage)
- Violations of antitrust law
- Violations of anti-money laundering provisions
- Violations of one of the grounds of discrimination set out in the German General Equal Treatment Act (AGG)
- Bullying, stalking, sexualised violence
- Violations of due diligence obligations under human rights law
- Violations of guidelines for awarding contracts
- Violations of internal rules, especially compliance policies
- Intentional privacy breaches and intentional violations of legal or official information security requirements
- Breaches of professional secrecy, sharing of confidential information
- Violations of occupational health and safety regulations, quality assurance policies or environmental regulations
Whistleblowing process
Upon receiving a whistleblowing report, the Confidential lawyer reviews the information for plausibility. If a legal violation or breach of internal codes of conduct – such as in respect of compliance policies – is suspected, he consults with the whistleblower and forwards the report, anonymised if necessary, to the Legal department of nobilia-Werke J. Stickling GmbH & Co. KG. The Confidential lawyer accompanies the process, while the Legal department sets about investigating the information received. The legal assessment of the facts under investigation and determination of appropriate measures for eliminating and avoiding incorrect business practices are undertaken together with the Confidential lawyer. At the latest following conclusion of the process, the whistleblower is provided with an update within the limits of what is legally possible. In addition, the whistleblower may request an update at any time during the process.
Whistleblower anonymity and protection
Any whistleblower wishing to remain anonymous is afforded such protection at all times. Therefore, the Confidential lawyer may forward anonymised reports to nobilia-Werke J. Stickling GmbH & Co. KG. All communication is then handled via the Confidential lawyer, who is obliged to maintain professional secrecy.
Whistleblower protection is a key aspect when dealing with reports. Whistleblowers are especially protected by the zero-tolerance approach taken to any reprisals directed or threatened against them.
A whistleblower’s wish to protect their identity runs counter to the interest of the person affected by the report in the disclosure of the facts. Therefore, a zero-tolerance approach is taken to deliberate abuse of the option to make complaints and whistleblowing reports – in other words, intentional false declarations in particular. In the event of intentional abuse of the whistleblowing system, the Confidential lawyer may, by way of exception, disclose the whistleblower’s identity to the company.
