Compliance

Anyone can contact the ombudsperson who has indications of actual or suspected legal violations, breaches of the Code of Conduct, or violations of policies related to a company within the Piepenbrock Group.
This applies to employees of these companies, members of corporate or management boards, as well as business partners or third parties.

The ombudsperson accepts reports on actual or perceived violations of laws, the Code of Conduct, or company policies that have already occurred or are highly likely to occur.
Reports can also be made regarding human rights and environmental risks, as well as violations of human rights or environmental obligations arising from the economic activities of a company within the Piepenbrock Group or of a direct or indirect supplier.

However, the ombudsperson is not available for general complaints, product and warranty inquiries, or individual legal advice.
Reports should only be submitted when the informant has reasonable grounds to believe that the information reported or disclosed by them is true. Deliberately false reports may lead to criminal liability or liability for damages for the informant. In case of doubt, relevant facts should be presented as assumptions, evaluations, or statements made by other persons.

The identity of the informant is protected by law, contractual agreements with the contracting companies, and the attorney-client privilege. The identity of the informant is only disclosed to the company if disclosure is necessary for follow-up measures and the informant explicitly agrees. The identity of an informant who intentionally or grossly negligently reports false information is not protected.

The ombudsperson also accepts anonymous reports. For effective investigation, it may be necessary to ask follow-up questions to the informant. Therefore, the ombudsperson will encourage the informant to provide their contact information for any follow-up inquiries. The identity of the informant will be treated confidentially.

The ombudsperson is an attorney of the company. Therefore, the company bears the costs. However, anyone who reports deliberately or grossly negligently false information causing harm is obliged to compensate for the damage.

The ombudsperson will document the report and confirm receipt of the report to the informant within seven days. They will assess the validity of the report and, if possible and necessary, ask follow-up questions to the informant.
The ombudsperson will provide a summary of the report, a recommendation for follow-up actions, and all necessary information for follow-up actions while ensuring confidentiality to the person or department responsible for compliance within the company. This entity is responsible for further processing and implementing corrective actions.

The ombudsperson will provide feedback to the informant within three months of the receipt confirmation, including planned or already implemented corrective actions and the reasons for those actions. However, if providing feedback would adversely affect the rights of individuals mentioned in the report or impede or prevent internal investigations, feedback may be omitted or provided without specifying corrective actions or reasons, as an exception.

A verbally submitted report will only be forwarded to the person or department responsible for compliance within the company if the informant explicitly consents. The informant may also decide not to disclose any information after a confidential conversation.

Employers are not allowed to disadvantage or threaten employees in response to the submission of a report or the assistance in submitting a report, provided there were reasonable grounds to believe that the reported or disclosed information is true. There is a so-called burden of proof reversal. For example, if an employee is terminated after submitting a report, the employer must prove that the termination was not due to the submission of the report.