Take action – don’t look the other way! Together, we can protect our corporate group

Why should I submit a report?

Compliance with statutory, social and internal company rules is part of a positive and open company culture.

Perhaps you are aware of damaging behaviour or risks that could endanger the company. Your report could help reveal possible financial damages or avoid harm to our image at an early stage. In this way, we secure the long-term success of the company and the continued existence of the jobs it provides together!

What sort of reports will help your organisation?

Reports about violations of legal regulations and internal company rules will be recorded and forwarded.

You will be given detailed information on the possible categories of a report during the reporting process.

What is the process for submitting a report? How do I set up a postbox?

If you wish to submit a report (either giving your name or anonymously), click the “Submit report” button at the top of our introduction page.

The reporting process consists of four steps:

First, you will be asked to read some information on the protection of your anonymity and answer a security query. On the following page, you will be asked about the category of your report. On the report page, you can elaborate on your report in your own words and answer simple multiple-choice questions about the case. You can enter up to 5,000 characters into the free text field, which corresponds to a full page. You may also submit a file of up to 5 MB to support your report. Please bear in mind that documents may contain information about the author. Following the submission of your report, you will receive a reference number to confirm that you have sent this report. You can then can set up your own secured postbox. You will use this postbox to receive feedback, answer questions and find out about the progress of your report. If you already have a secured postbox, you can go straight to it via the “Login” button. First, you will have to answer a security query.

If you already have a secured postbox, you can go straight to it via the “Login” button. First, you will have to answer a security query.

As long as you do not enter any data from which conclusions about your person can be drawn, the technology of the BKMS^® System will protect your anonymity. If the report allows conclusions to be drawn, the examiners will anonymise them in such a way that the statutory provisions on whistleblower protection are complied with.

How do I receive feedback and remain anonymous at the same time?

The overriding principle of the BKMS^® System in use is the protection of the whistleblower. The system’s anonymity protection function is certified by an independent body.

When setting up your secured postbox, please select your own pseudonym/ user name and password. If you lose your login information, please submit a new report and set up a new postbox. If possible, please provide the reference number of your previous report. The new postbox will not contain anything associated with your previous report.

The report is kept anonymous through encryption and other specialised security measures. If you wish to submit your report anonymously, you should not submit any personal information or any information that can be traced back to you.

Via the secured postbox, an examiner will give you feedback about what is happening with your report or ask you questions if some details are still unclear – you will continue to remain anonymous throughout the dialogue.

What kind of report can I submit through this system?

Reports on behaviour which violates regulations or violations of the law help BITMARCK. Please use the whistleblowing system to report criminal offences, such as corruption, breaches of trust, fraud, theft, property damage, violations of anti-trust law, anti-competitive violations, information security or data protection violations and other breaches of internal regulations. You will be given detailed information on the possible categories of a report during the reporting process.

If you are dissatisfied with the customer service or a BITMARCK service, please get in touch with the contact persons listed in your contract documents or call our Service Desk at 0800-BITMARCK (0800-24862725). For all other concerns, please send an email to info@bitmarck.de.

Rules of procedure for the complaints process according to the German Supply Chain Act (LkSG)

according to Section 8 (2) German Supply Chain Act (LkSG)

Our complaints process is intended to enable individuals to submit reports if they identify actual or potential issues in the area of human rights or environmental law. This may include problems in our supply chains, as well as in our own business activities. This complaints process describes the topics to which reports may relate, how to submit reports and what happens once you have submitted a report.

We are happy to answer questions about the process, either directly via the whistleblowing system or via the contact option under “Responsibility for the complaints procedure”.

Scope

In principle, all issues relating to human-rights or environmental violations can be reported via this whistleblowing system.

Specific examples:

Human rights violations:

• Child labour
• Forced labour and slavery
• Discrimination and unequal treatment
• Violation of freedom of association
• Refusal to pay an appropriate wage
• Working conditions that pose a risk to health
• Illegal forced eviction and illegal seizure of land
• Illegal use of private or public security forces
• Pollution of water, soil or air that can contribute to a violation of human rights

Environmental violations:

• Use of mercury (as per the Minamata Convention)
• Use of persistent organic pollutants (as per the Stockholm Convention)
• Non-environmentally sound storage, handling, import and export of hazardous waste (as per the Basel Convention)

Submitting reports and complaints

We recommend submitting reports via our digital whistleblowing system:

https://www.bkms-system.com/bitmarck

Reports may be submitted in the respective preferred language. Reports may be submitted at any time around the clock. Whistleblowers may remain completely anonymous if they wish. If whistleblowers choose to disclose their identity, confidentiality is ensured and personal data is protected.

The system enables whistleblowers to remain in contact with our company after submitting a report, even if they choose to remain anonymous. The use of the system is of course free of charge for the whistleblower.

How the process works

Processing of all of the incoming reports follows a structured procedure, which is described below.

1. Receipt of the report

Whistleblowers will receive an acknowledgement of receipt within seven days of receipt of the report.

2. Assessing the report

The content of the report will then be assessed. In this phase, questions may arise which will be clarified by means of a dialogue with the whistleblower. The process will proceed, based on the contents. If a complaint is rejected, the whistleblower will be informed of why.

3. Clarifying the facts

If the process continues, the issue will be discussed and assessed with the whistleblower. Optionally, a process for the amicable settlement of the dispute may arise.

4. Developing a solution

A proposal for a solution is worked out in close contact with the whistleblower. If relevant, arrangements for redress will be made.

5. Corrective action

Corrective action may be required to resolve reported issues. When corrective actions are agreed upon, these are implemented and followed up.

6. Review and closure

The result of the process will be evaluated together with the whistleblower. In particular, this also concerns the satisfaction of the whistleblower with the course and result of the process.

The length of the process depends heavily on the circumstances of each case and can range from a few days and weeks to a few months. As a matter of principle, we try to guide the process to a satisfactory solution as efficiently as possible. In addition, we always try to keep the whistleblower informed about the measures taken and the further course of the process. For this purpose, we recommend that whistleblowers who use the digital whistleblowing system log in regularly and check their own case for new messages.

Amicable settlement

For some complaints, it may be appropriate to involve a neutral and mediating third party. In this way, we would like to contribute to finding a satisfactory solution that can be supported by all parties. If it becomes apparent during the process that an amicable settlement to the dispute may make sense, we will endeavour to involve such a neutral party.

Responsibility for the complaints process

Centrally responsible for our complaints process and primary contact person(s) for questions or comments:

BITMARCK Holding GmbH
Team Compliance
Michael Lechermann and Patrick Ohnesorg
Telefon:+49 201 1766-2910
E-Mail: compliance@bitmarck.de

We also recommend that whistleblowers use the option of communicating via our digital whistleblowing system to address questions and comments directly to the responsible person.

Protection from discrimination or punishment

We work to ensure that whistleblowers do not face any discrimination or punishment as a result of their report. Reprisals based on complaints or reports will not be tolerated. If the whistleblower is employed by our company, this includes protection against termination, demotion, suspension, threats, harassment or any other type of discrimination with respect to an employee’s working or employment conditions.

If the whistleblower is employed, for example, by a supplier, we will work with the supplier to ensure that the person enjoys a comparable level of protection. To ensure that the whistleblower is not subjected to any discrimination, punishment or similar retaliation, we will endeavour to maintain contact with the whistleblower beyond the closure of the process.

Munich, 20 December 2023