Reporting system Declaration of principles
Seitz GmbH is committed to the principles of sustainability and pursues the goal of fulfilling its responsibility towards future generations. We attach great importance to ensuring that our products and business processes meet the highest ecological, economic and social standards and are always based on state-of-the-art technology.
Our strategies and activities are based on universal principles in the areas of human rights, labor standards, environmental protection and anti-corruption. We are also committed to social goals.
It is a fundamental expectation of all employees, including temporary and external employees and other stakeholders such as customers and suppliers, that they adhere to these principles. These are in line with Seitz GmbH's corporate values and are detailed in the Code of Conduct and the Supplier Code of Conduct.
Seitz GmbH encourages all stakeholders, including employees, customers, suppliers and partners, to promptly report any behavior that they reasonably believe violates applicable laws, regulations, internal control policies, company policies or the Code of Conduct.
The principles of this policy do not affect the reporting obligations to the competent judicial, supervisory or regulatory authorities in the countries in which Seitz GmbH operates.
Seitz GmbH Gutenbergstraße 1-3, 65830 Kriftel, Germany
December 12, 2023
Alexander Seitz (Managing Director)
Scope of application, responsibilities and definitions
1. General scope
Seitz GmbH encourages current and former employees, interns, applicants, customers, suppliers, partners and other stakeholders to report any behavior that they reasonably believe violates laws, regulations, internal control policies, company policies or the Code of Conduct.
The Whistleblower Policy applies to concerns regarding suspected or actual criminal behavior, unethical behavior or other misconduct within Seitz GmbH. This includes, but is not limited to, accounting, tax evasion, money laundering, environmental violations, human rights violations, corruption and other violations of law.
Personal complaints such as harassment or bullying are not covered by this whistleblowing policy. Seitz GmbH has its own procedures for employee complaints. Nevertheless, we encourage employees to report personal concerns under this policy if internal procedures fail or the employee fears retaliation.
2. Seitz GmbH Compliance Manager
The Seitz GmbH Compliance Manager is responsible for the whistleblower policy, the protection of whistleblowers and the investigation of cases. This person defines, implements and develops the whistleblower system at Seitz GmbH under the supervision of the management.
During the investigation, the Compliance Manager reports regularly to the management and provides summaries. All reported cases are treated in strict confidence and only the Compliance Manager is authorized to disclose information if necessary to process the case.
3. Confidentiality
All reported cases are treated as strictly confidential, regardless of the reporting channel. Only the Compliance Manager may disclose the existence and details of the report to other internal or external parties if this is necessary to process the case. Persons who are informed about the report are obliged to maintain strict confidentiality.
4. Anonymity
Whistleblowers have the right to remain anonymous. Seitz GmbH recommends using the EQS Integrity Line as a reporting channel to ensure anonymity throughout the process. If another reporting channel is used, Seitz GmbH guarantees that only the Compliance Manager and the original recipient of the report know the identity of the whistleblower. The identity will only be disclosed with the express written consent of the whistleblower.
5. Public announcement
Whistleblowers have the right to make reports public if other reporting channels do not yield results. This can be done via internet platforms, social media or communication to media, public officials or civil society organizations. However, Seitz GmbH reserves the right to take legal action if an unjustified public disclosure is made.
Reports of misconduct
6. Report
Reports must be detailed and well documented to enable effective verification. Information such as a precise description of the incident, date and location, names of persons involved and relevant documents should be included. If no documentation is provided in the initial report, further information can be provided during the investigation.
7. Reporting channels
Seitz GmbH offers various reporting channels for whistleblowers:
7.1 Digital platform
Seitz GmbH has set up a digital whistleblower platform with EQS. Whistleblowers can submit reports via the EQS Integrity Line and also communicate anonymously with the compliance manager. This ensures anonymity through encrypted data transmission.
7.2 E-mail
Cases can be reported anonymously to compliance[at]seitzgmbh[dot]com. However, anonymity is not fully guaranteed.
7.3 Post
Cases with evidence can be sent to:
Strictly confidential
Seitz GmbH
Compliance Manager
Gutenbergstraße 1-3
65830 Kriftel
should be sent. Anonymity can be maintained, but communication with the compliance manager could be restricted without disclosure of identity.
7.4 Personal
Cases can be reported personally to the Seitz GmbH Compliance Manager, the management or the HR department. Anonymity is not guaranteed in this case.
All cases are forwarded by the Compliance Manager to the EQS Integrity Line for documentation purposes.
Investigation
8. Investigation process
The investigation process includes:
- 1. the whistleblower learns of (suspected) misconduct and collects evidence.
- 2. the report is submitted via the defined reporting channel. The Compliance Manager checks the validity of the report.
- 3. the Compliance Manager conducts a prompt and thorough investigation and reports directly to the management.
- 4. upon completion of the investigation, the Compliance Manager prepares a report and communicates the results to the relevant corporate functions.
- 5. the management receives regular interim reports during the investigation.
- 6. whistleblower protection
Seitz GmbH does not tolerate threats, retaliation, punishment or discrimination against whistleblowers. Employees who report concerns in good faith should not fear retaliation. Any retaliation should be reported to the Human Resources Department or the Compliance Manager. Seitz GmbH reserves the right to take action against retaliation
9. Malice
Seitz GmbH reserves the right to take legal action against individuals who make false, unfounded or opportunistic reports in bad faith
Processing of personal data
Personal data is processed in accordance with the applicable data protection regulations, including the GDPR. Only the data strictly necessary for the verification and management of reports is processed. The Compliance Manager monitors data processing and only trained employees are appointed as data processors.
Seitz GmbH guarantees the protection of personal data against destruction, loss or unauthorized disclosure. Access to data is carried out with confidentiality in mind, and access authorizations are revoked once the investigation has been completed. The retention of documents is carried out in accordance with legal requirements and ends once the procedures have been completed.