The whistleblower system is operated by EQS (EQS Group AG, Hardturmstrasse 11, 8005 Zurich, Switzerland – hereinafter referred to as "EQS") on behalf of ESG ELEKTRONIKSYSTEM- UND LOGISTIK-GMBH, Munich ("ESG"). As the operator, EQS does not have access to the information recorded.
The use of the whistleblower system is voluntary.
Whistleblowers can record the following information using Integrity Line:
- Name (voluntary)
- Information about the incident and the companies, organizations or persons affected
The whistleblower system is not intended to replace standard methods of communication. Instead, it is to be used solely for reporting serious suspicion of legal violations or for those cases in which strict confidentiality of information must be ensured. Reports can therefore also be submitted anonymously.
Please note that for legal reasons, reports cannot be processed unless sufficiently specific indications are provided. Note that deliberate misreporting and slander can have legal consequences. This does not apply to reports that have been submitted in good faith and that are subsequently determined to be false.
The whistleblower system is protected by a variety of technical security features. All confidential information is encrypted to ensure that all reports are protected. The system can be accessed exclusively via secured connections; data transmission is protected by a SSL certificate. Within the system, access is controlled via an authorization concept. No IP addresses are stored in order to ensure the anonymity of the whistleblower.
Questions and information entered in the whistleblower system are viewed, evaluated and provisionally processed (preliminary review) by the compliance officer of ESG and/or his or her representative. In case of notifications regarding data protection the data protection officer is automatically involved. The compliance officer or his or her representative reports directly to the management board, and in exceptional cases, to the advisory board to ensure the highest possible level of confidentiality at all times.
However, depending on the assessment or evaluation of the report, further persons, for example from the audit and legal departments, as well as external persons, may be involved or requested to investigate the report. In such cases, these persons are also granted access to the incident. Depending on the content of the incident, processing can also be passed on to the local organization, as long as it is not affected by the contents of the report.
Note that, at a certain point, ESG may be required to pass on the information to government agencies responsible for the prosecution of criminal offenses.
Under the law, ESG is obligated to notify the accused party that allegations have been made against that person, as long as the notification no longer jeopardizes the further investigation of the allegations. To ensure that the person accused in the report can exercise his or her own rights, the person will be informed of the allegations as soon as the investigation permits, while preserving the anonymity of the reporting person. He or she then has the right to comment on the allegations.
Once the incident is closed, personal information will not be retained any longer than legally permitted.
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