AIMS OF THE WHISTLEBLOWER SYSTEM

The aims of the whistleblower system are as follows:

• Protection of the company and employees
• Compliance with values, guidelines, laws and regulations
• Fighting corruption, white-collar crime and other illegal activities or unethical behavior
• Clear statement from the management encouraging and supporting whistleblowers
• Support of the compliance program thanks to risk minimization
• Compliance with the EU Whistleblowing Directive and other national laws
• Enabling whistleblowing independent of location, time and language
• Ensuring 100% anonymity of the whistleblower
  
  

COMMISSIONED PERSONS

At FIS-ASP, the Compliance Manager or their deputy is responsible for receiving the report (= person of trust). They

• anonymize the person-related data contained in the report,
• communicate with the whistleblower if contact data exists and
• coordinate the report within the company.
  
  

ANONYMIZATION OF PERSON-RELATED DATA

Anonymization plays an important role in the whistleblower system. The possibility of submitting an anonymous report lowers the inhibition threshold for whistleblowers. Experience also shows that many anonymous whistleblowers do reveal their identity in the course of the dialogue, provided they feel safe and taken seriously.  Therefore, reports received via the whistleblower system of FIS-ASP are anonymized by the person of trust.

The person of trust therefore removes any person-related data of the whistleblower or of persons named within the report. The whistleblower’s contact data will be kept under lock and key and only by the person of trust/compliance manager.

REPORTING CHANNELS

Various low-threshold reporting channels have been set up for submitting reports.

• By mail: Every whistleblower, whether internal or external, is able to send anonymous reports to the companies by mail. After receipt by the administration, letters are distributed internally for the attention of the Compliance Manager.
• By phone: Any whistleblower can make declarations by telephone. In order to ensure anonymity, the report should be received by persons of trust (= Compliance Managers).
  Phone: +49 9723 91 88-500 (reception; please ask to be connected to the Compliance Manager)
• E-mail: Each whistleblower is free to mail their report. Anonymity is then subsequently established by the receiving person (person of trust/Compliance Manager). Please send your e-mail to asp_compliance@fis-asp.de

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• Personal: Every whistleblower is free to seek personal discussion. Anonymity is then subsequently established by the receiving person (person of trust/Compliance Manager).

RESPONSE TIMES FOR CONFIRMATION TO THE REPORTER

Provided that the contact data is available, the whistleblower will receive an acknowledgement of receipt from the person of trust/Compliance Manager after seven days at the latest.
No later than three months after receipt of the report, the reporter receives a final notice from the person of trust/Compliance Manager.

PROCEDURE AFTER RECEIPT OF THE REPORT

After a report has been received via the whistleblower system and the Compliance Manager has sent the acknowledgment of receipt (if contact options are available), the report is anonymized.

The Compliance Manager evaluates the report and, depending on its severity, assesses whether an internal investigation is necessary. If this is required, an investigation team is formed. The latter reviews the necessary documents and, if necessary, conducts interviews with those involved. If necessary, the Compliance Management Committee can be consulted.

After completion of the investigation, suitable measures (corresponding to the causes) are derived and implemented, if necessary.

The whistleblower will receive a final notice from the Compliance Manager no later than three months after receipt of the report, provided that the contact data of the whistleblower is available.