Compliance

HWA AG's Whistleblowing Process in accordance with the German Whistleblower Protection Act (HinSchG)

This document sets out the whistleblowing process at HWA AG.

1. Foreword

With its Code of Conduct, HWA AG has committed itself to lawful conduct, sustainable management and the prohibition of any form of discrimination.

In accordance with the German Whistleblower Protection Act, HWA AG is required to implement a whistleblowing system that enables employees, managers, business partners and third parties to report incidents, actions and risks as outlined in sections 3 and 5 of this whistleblowing process.

HWA AG aims to create and further develop conditions – also with the help of the whistleblowing system – within which employees can act in compliance with laws, our Code of Conduct and our policies. Only when rules and norms are adhered to can we protect our company, our employees and other individuals from harm, while safeguarding those affected by misconduct. Adhering to laws and internal regulations is our top priority. When we identify misconduct or potential violations of regulations, we do not hesitate to address them directly. Our whistleblowing system allows reports of misconduct and violations to be made in a protected environment, including anonymously. Our whistleblowing system is available to both internal and external parties.

All employees, business partners and third parties are hereby given the opportunity to report violations. This allows us to mitigate undesired consequences and avoid similar misconduct in the future.

 

2. Responsibility

The responsibility for the whistleblowing process lies with the Executive Board of HWA AG. To guarantee absolute confidentiality and anonymity (if desired by the whistleblower), the Executive Board has installed a communication platform.

 

3. What violations ca be reported?

All criminal actions can be reported, as well as any other violations of laws, our Code of Conduct or internal company policies. In addition, risks related to human rights and the environment, as well as violations of human rights-related and environmental obligations, can be reported.

We kindly ask that only well-founded and serious reports be submitted. Deliberate false reports are prohibited.

In particular, we welcome reports regarding violations related to:

  • Discrimination
  • Sexual harassment
  • Money laundering
  • Theft
  • Bullying
  • Retaliation
  • Corruption/ compliance violations
  • Human rights violations 
  • Violations concerning environmental regulations and/or non-compliance with product-related environmental regulations
  • Unknown / other

 

4. Frequently asked questions:

How can a report be submitted?

To submit an anonymous report, please follow the steps outlined in section 1, "Submit a report": 
https://support.personio.de/hc/en-us/articles/12958595118109-Personio-Whistleblowing-for-reporters


You can access the whistleblowing system via the following link: https://hwa.personiowhistleblowing.com/report-a-case

What if I have a suspicion but am not entirely sure?

Violations are often uncovered through tips from people who were initially unsure of the facts. You don't need to know every detail; it is sufficient to report what you know.

What happens after a report is submitted, and will I receive a response?

Please allow us 7 working days to process your report. You will receive feedback on what is happening with your report via the account you created, or you may be asked for further details if anything is unclear. You will remain anonymous throughout the communication.

Please ensure you save your password!

You will not receive emails or notifications about responses to your report or updates. Therefore, it is essential that you save your password. You can track your report through the reporting page, where you must enter the password for your report.

How are incoming reports handled?

All incoming reports are reviewed by the Whistleblowing Manager, so that appropriate measures can be taken if necessary. This channel guarantees the confidential handling of all incoming reports and the protection of all parties involved.

How often can I contact the whistleblowing system?

You can contact the HWA whistleblowing system as often as you like. If you have additional information regarding an incident that has already been reported, you can update the incident report and provide further details. In section 2, "Case updates", you can learn how to access a previously submitted incident report:

https://support.personio.de/hc/en-us/articles/12958595118109-Personio-Whistleblowing-for-reporters#h_01HA7WK3X0ZEJXBEFGEJZ5N8NF

 

4. Process workflow

The whistleblowing system guarantees confidentiality, anonymity (if desired by the whistleblower) and compliance with the General Data Protection Regulation.

All reports submitted through the whistleblowing system are forwarded directly to the designated Whistleblowing Manager within the company. The whistleblower receives an acknowledgement of receipt no later than 7 days after submission. The Whistleblowing Manager can maintain contact with the reporting person through the whistleblowing system and request further information if needed.

Procedures in accordance with the German Whistleblower Protection Act

The Whistleblowing Manager examines whether a criminal act or any other violation of laws or internal company policies has occurred.

  • If the Whistleblowing Manager does not find a violation, the process will be closed and the whistleblower will be informed accordingly through the whistleblowing system.
  • If the Whistleblowing Manager finds a violation, they will take over the process and initiate the necessary subsequent steps. Feedback will be provided to the reporting person via the whistleblowing system within three months at the latest. The feedback should include a report on follow-up measures planned and already taken and the reasons for them, provided that internal investigations or inquiries are not compromised and the rights of people who are the subject of a report or are named in the report are not affected.

 

5. Other information

The whistleblowing system guarantees confidentiality, anonymity (if desired by the whistleblower) and compliance with the General Data Protection Regulation. Effective protection against disadvantage or punishment is ensured under the responsibility of the Whistleblowing Manager. The documentation of the process is to be deleted two years after its completion.

The effectiveness of the complaint procedure is reviewed at least once a year and on a case-by-case basis.