During the use of BKMS® Incident Reporting, a text file (called a “session cookie”) is saved on your computer containing only the number of your session. This is necessary for technical reasons in order to establish the connection to a security-certified server. The “session cookie” does no damage to your computer, it does not access your data and has no relation to the contents of your report. If you close all browser windows after submitting your report, the “session cookie” will expire and be automatically deleted.
Compliance concerns us all!
As a family company, the Pfeifer & Langen Sugar Group has always been guided by values, resulting in a good reputation among employees, customers and suppliers.
For this reason, the topic of “compliance” with legal and company-internal rules is considered very important at the company.
Should there be reason to question whether laws or regulations have been followed, a personal conversation with those involved or the compliance officer is generally the best way to express these concerns and arrive at a good, mutual solution.
“Compliance with legal and company-internal rules is an important component of our company's success. Compliance concerns us all. Please assist us and share your compliance concerns with us in a personal conversation or via the whistleblowing system.”
However, if this method appears unsuitable in individual cases, we would like to offer employees, customers and suppliers this web-based whistleblowing system (BKMS® Incident Reporting) as an additional way to share their concerns on compliance topics. Reports can be submitted by name or anonymously. The system is operated by an external provider that itself has no access to the report contents. The recipient of the report is the Director of Legal & Compliance at the Pfeifer & Langen Sugar Group. All incoming reports will be investigated carefully. Whistleblowers who submit a specific report in good faith are protected and will not be subjected to any disadvantages.
Thank you very much for your support and dedication!
Executive management of Pfeifer und Langen GmbH und Co. KG
Reports in the whistleblowing system should be restricted to topics such as anti-trust law violations, corruption/bribery and accepting bribes, property crimes (such as fraud and breach of trust, theft and embezzlement), disclosure of business and company secrets or other significant accusations. The whistleblowing system may not be used to knowingly submit inapplicable, insulting or slanderous reports.
Your reports will be accepted and carefully investigated.
You will receive more detailed information during the reporting process.
What is the process for submitting a report? What is a postbox and how do I set up one?
If you wish to submit a report (either by name or anonymously), click the “Submit report” button at the top of our introduction page.
The reporting process consists of 4 steps:
First, you will be asked to read the information on the protection of your anonymity and to 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 questions about the case by selecting a single response. 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 can 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.
Please subsequently set up your own secured postbox. You will receive feedback from us via this postbox, including answers to questions and information about the progress of your report.
If you already have a secured postbox, you can access it directly 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® Incident Reporting will protect your anonymity.
If you connect to the web-based whistleblowing system via the network of the Pfeifer & Langen Sugar Group, the IT department can theoretically track whether employees have accessed the BKMS® page. However, it cannot be determined whether a report was submitted or whether the access took place merely for test purposes, for instance.
The overriding principle of the BKMS® procedure 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. These login credentials are not visible for anyone but yourself. If you lose your login details, please submit a new report and set up a new postbox. If possible, please provide the reference number of your initial report. As this will be a new postbox, you cannot see the content of your previous report.
Your report is kept anonymous through encryption and other special security routines. You will never be asked for personal information at any time during the reporting process. Do not submit any information that can be traced back to you. Please do not use any technical device, for example a PC or smartphone, that has been provided by your employer, to submit your report.
Via the secured postbox, an examiner will provide you with feedback on what is happening with your information or ask questions if details still need to be clarified - you will continue to remain anonymous during the dialogue. We are interested in reports to avoid damages, not in you as a whistleblower.
Pfeifer & Langen GmbH & Co. KG Aachener Straße 1042 a 50858 Cologne
Cologne District Court: HRA 13089 VAT ID no.: DE 123484020
Represented by the personally liable managing partner:
Pfeifer & Langen Zucker-Beteiligungen GmbH
Michael Schaupp Uwe Schöneberg
Cologne District Court: HRB 14276
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® Incident Reporting) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of Pfeifer & Langen. The processing of personal data in the BKMS® Incident Reporting is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to Pfeifer & Langen, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
The party responsible for data protection in the whistleblowing system is Pfeifer & Langen GmbH & Co. KG (hereafter also: “Pfeifer & Langen”). The reporting system is operated by a specialised company, Business Keeper AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Pfeifer & Langen.
Personal data and information entered into the reporting system are stored in a database operated by Business Keeper AG in a high-security data centre. Only Pfeifer & Langen has access to the data. Business Keeper AG and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at Pfeifer & Langen.
Pfeifer & Langen has appointed a data protection officer. Questions on data protection at Pfeifer & Langen can be sent to firstname.lastname@example.org.
Type of the collected personal data
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
your name, if you choose to reveal your identity,
whether you are employed at Pfeifer & Langen, and
the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance department of Pfeifer & Langen and are always handled confidentially. These employees of the Compliance department of Pfeifer & Langen will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of Pfeifer & Langen or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
Rights of the data subjects
According to European data protection law, you and the persons named in the report have the right to inquiry, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning them. If the right of objection is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required is deleted immediately. In addition, you have the right to lodge a complaint with a supervisory authority.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists or it is required by law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® Incident Reporting, a cookie is stored on your computer that merely contains the session ID (a so-called null cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the responsible employee at Pfeifer & Langen either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible employee of Pfeifer & Langen. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.