Whistleblower Protection Whistleblowing System
This document defines the whistleblowing process of HWA AG.
1. Preface
With its Code of Conduct, HWA AG is committed to lawful behavior, sustainable management, and the prohibition of any form of discrimination.
In accordance with the German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG), HWA AG is required to implement a whistleblowing system that enables employees, managers, business partners, and third parties to report incidents, actions, and risks in accordance with Sections 3 and 5 of this whistleblowing process.
HWA AG pursues the objective – also through the whistleblowing system – of creating and continuously developing a framework in which employees act in compliance with laws, our Code of Conduct, and our internal policies. Only by adhering to rules and standards can we prevent harm to our company, our employees, and other individuals, while also protecting persons affected by misconduct.
Compliance with laws and internal regulations is our highest priority. If we become aware of misconduct or potential violations, we will not hesitate to address them directly. Through our whistleblowing system, reports regarding misconduct and violations can be submitted within a protected framework – including anonymously. Our whistleblowing system is available both internally and to external third parties.
This system provides employees, business partners, and third parties with the opportunity to report violations. In doing so, undesirable consequences can be limited and similar misconduct can be prevented in the future.
2. Responsibility
Responsibility for the whistleblowing process lies with the Management Board of HWA AG. In order to guarantee absolute confidentiality and anonymity (where requested by the whistleblower), the Management Board has implemented a dedicated communication platform.
3. Which Violations Can Be Reported?
In particular, all criminal offenses as well as any other violations of laws, our Code of Conduct, or internal company policies may be reported. Reports may also concern human rights and environmental risks, as well as breaches of human rights-related or environmental obligations.
We kindly ask that only well-founded and serious reports be submitted. Deliberately false reports are prohibited.
In particular, reports relating to the following may be submitted:
- Discrimination
- Sexual harassment
- Money laundering
- Theft
- Bullying / mobbing
- Retaliation
- Corruption / compliance violations
- Human rights violations
- Violations related to environmental regulations and/or non-compliance with product-related environmental requirements
- Unknown / Other
4. Frequently Asked Questions
How can a report be submitted?
To submit an anonymous report, please follow the steps listed under “1. Submit a Report” at the following link:
To access the whistleblowing system, please use the following link:
HWA Whistleblowing System
What if I suspect misconduct but am not entirely sure?
Violations are often identified through reports from individuals who were initially uncertain about the facts. You do not need to know every detail; it is sufficient to report what you know.
What happens after I submit a report, and will I receive feedback?
Please allow us up to 7 working days to process your report. Through the account you created, you will receive feedback regarding the status of your report or be contacted with follow-up questions should further clarification be required. Throughout the entire communication process, you will remain anonymous.
Please make sure to save your password!
You will not receive any emails or notifications regarding replies to your report or status updates. Therefore, it is essential that you save your password. You can track your case through the reporting page, where you will need to enter the password associated with your report.
How are incoming reports handled?
All incoming reports are reviewed by the Whistleblowing Manager so that, where necessary, appropriate measures can be initiated. 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 may contact the HWA whistleblowing system as often as you wish. If you have additional information regarding an already submitted report, you may update the case and add further details. Under section “2. Updating Cases,” you can find information on how to access a previously submitted report:
4. Process Procedure
The whistleblowing system guarantees confidentiality, anonymity (where requested by the whistleblower), and compliance with the General Data Protection Regulation (GDPR).
All reports submitted through the whistleblowing system are forwarded directly to the designated Whistleblowing Managers within the company. The whistleblower will receive an acknowledgment of receipt no later than 7 days after submission. The Whistleblowing Manager may remain in contact with the reporting person through the whistleblowing system and may request additional information if required.
Procedure in accordance with the German Whistleblower Protection Act
The Whistleblowing Manager reviews whether a criminal offense or another violation of laws or internal company policies has occurred.
If the Whistleblowing Manager determines that no violation has occurred, the case will be closed and the reporting person will be informed accordingly through the whistleblowing system.
If the Whistleblowing Manager identifies a violation, the case will be taken over and the necessary further steps will be initiated. Feedback will be provided to the reporting person through the whistleblowing system no later than three months after submission. Such feedback shall include information on planned or already implemented follow-up measures and the reasons for these measures, provided that this does not affect internal investigations or infringe upon the rights of the persons concerned or named in the report.
5. Miscellaneous
The whistleblowing system guarantees confidentiality, anonymity (where requested by the whistleblower), and compliance with the GDPR. Effective protection against disadvantages or retaliation is ensured through the responsibility of the designated Whistleblowing Manager. Documentation related to the procedure will be deleted two years after completion of the case.
The effectiveness of the complaints procedure is reviewed at least once per year and additionally whenever required by specific circumstances.