In principle, all employees of a company can report violations, including interns, freelancers or those working in temporary employment. If the company or public institutions open the system for this purpose, business partners, suppliers, former employees or applicants can also submit reports. Regardless of the status of the whistleblower, all of these groups receive the confidentiality and protection afforded by the law.

Companies and public institutions must treat your identity and the reported violation confidentially. The information is only shared with a small group of people for research purposes. You can choose whether to reveal your identity or remain anonymous. Depending on the legal situation, anonymous reports may not legally have to be processed. However, serious information will usually always be taken into account.

Because the information you disclose may lead to investigations and (possibly criminal) consequences for those affected, you must believe that the information reported is true. Deliberately stating false facts or false suspicions can result in criminal consequences for the whistleblower. In this case, you as a whistleblower are not protected. However, you will not face any consequences if you provide the information to the best of your knowledge and belief and in good faith, even if the information later turns out to be incorrect. Your motives for reporting it are irrelevant, as long as you believe they are truthful.

Please note that as a whistleblower you are not allowed to disclose any information if you are subject to a legally mandated professional obligation of confidentiality, such as as a doctor or tax advisor.

In addition, in certain circumstances, those who learn of the report may be required by law to fully release reported information to government agencies. This can be the case, for example, if there are legal requirements to involve authorities in areas affected by a tip. The company can also be forced by investigative authorities (e.g. as part of a search) or a court to reveal information and the identity of the whistleblower.

In order for a notice to be checked and processed correctly, it is important that you provide as specific information as possible and describe the violation as precisely as possible.

The best way to do this is to answer the questions Who? – What? – Where? – How? and when? – In order to ensure a quick clarification, it would be helpful if you were available to answer any questions. Whether via the whistleblower system directly, by telephone or via an email address is up to you. You remain anonymous when communicating via the whistleblower system. To do this, create an anonymous account yourself after submitting the tip. You will be automatically instructed to do so after submitting the tip. Two-way communication with the company can then take place via this account.

You should also note that your tip will be reviewed by people who may not have expertise in your field. Please try to describe the matter as clearly and objectively as possible. If you have any further questions about the procedure or the White Sparrow whistleblower system, you can write an email to the White Sparrow team at [email protected] with your questions. We would be happy to inform you, non-bindingly and confidentially, about the process of making a report.

1. On the next few pages you will be asked in a form to describe the violation in as much detail as possible and to provide important information. Information such as your name or position is not mandatory.

2. If you provide your name and contact details, you will receive feedback on the follow-up measures taken within three months at the latest.

3. Please understand that processing takes time depending on the extent of the notice. We take your concern seriously and would like to examine it with due care. Questions can also be directed to you beforehand. These can be sent to you directly via the system without revealing your identity.

4. During the investigation, those involved who are necessary are involved and asked to assist. Depending on the information reported, the company is obliged to involve state authorities such as public prosecutors or supervisory authorities. – If they legally force the company to provide all information about the tip, the identity of the whistleblower would also have to be disclosed.

5. After the investigation has been completed, the whistleblower will receive information about how the investigation was completed and with what follow-up measures.

The White Sparrow whistleblower system is provided by MKM Compliance GmbH as an independent partner. The information is recorded using software developed in a highly secure banking environment and stored in technically secure data centers in Germany without access from abroad. The reported information is stored exclusively on servers in data centers that are certified according to DIN ISO 27001/27002, ISO 22301 and 27018, SOC 1, SOC 2 and SOC 3. The metadata that is absolutely necessary for transmission, such as IP addresses or network and device specifications, is only stored on these servers for a short time and then deleted without the companies or employees of MKM Compliance having access to it. In addition, the system is set up in such a way that an IP address cannot be associated with a submitted report. Even accessing the data means that it is no longer possible to assign it to a note. You decide for yourself whether you remain anonymous or provide information about yourself. In any case, message content is transmitted securely in encrypted form.

A report can be made in text form here in the whistleblower system. If the company or public institution has set it up, tips can also be submitted via email or voice to a telephone mailbox. If necessary, visit the website of the company concerned. All incoming tips are entered into this whistleblower system and processed there in the protected environment. – If the company concerned provides further opportunities for submitting a report, it may have published this itself.