Rules of Procedure

for the Whistleblower and Complaints System


The Waelzholz Group takes compliance violations seriously. It has therefore established an appropriate complaints procedure to enable whistleblowers and third parties to report violations and risks in the supply chain without fear of reprisals.

Various communication channels are available for reporting, as shown in the following overview. The first point of contact is usually the compliance officer. In some cases, it is possible to discuss the information with the ombudsman. The ombudsman is independent and bound to secrecy.

Receipt of a tip will be acknowledged within seven days. The contents are then examined and any necessary investigations are carried out. Depending on the results of this examination, any compliance violations will be stopped and sanctioned. The whistleblower will be informed about the progress of the whistleblowing process after three months at the latest.

Whistleblowers are assured of confidentiality and, if they wish, anonymity, so that not even the whistleblower knows who the whistleblower is. This does not incur any costs for the whistleblower.

The effectiveness of the grievance procedure is reviewed at least once a year and on an ad hoc basis.

Dealing with your tip


An incoming tip to the compliance officer is first assessed. Is there a compliance violation and how serious is the allegation? Is there perhaps still information missing for the assessment? In particularly serious cases, the management is informed, if permissible. The allegation is then clarified internally, evaluated and a decision is made on how to proceed. Any violations that are identified will be remedied and sanctioned appropriately.

An incoming tip to the ombudsman is first evaluated. Then a report is made to the person responsible for compliance in the company. The whistleblower decides whether or not his identity should be disclosed to the company. The ombudsman is an external lawyer who is also bound to secrecy vis-à-vis the company. He must not disclose your identity or any clues to your identity unless you allow him to do so. He is available for a confidential discussion of the tip-off.