Compliance

The compliance program of the AFT Group aims to ensure compliance with all legal provisions as well as internal company guidelines. It sets standards that must be met by the company’s management and that go beyond the legal requirements.

This comprehensive program places increased demands on company management that go well beyond general legislation. It is intended to ensure continuous monitoring and compliance with legal, ethical and internal company standards in order to promote responsible, sustainable and ethical business operations.

Declaration of Human Rights Principles

We are aware of our social responsibility and the obligation to uphold human rights. In the conduct of our business activities, we always put these principles at the forefront and ensure strict compliance with human rights within our company. We expect this commitment from our business partners as well.

Declaration of Human Rights Principles

Business Partner Code

Our Code is based on the corporate principles that apply to all employees. The basis of our actions, both within the AFT Group and in relation to customers, suppliers and other business partners and stakeholders, is compliance with rules and the practice of ethical conduct. We are particularly committed to fair business relationships based on trust.

Business Partner Code

Whistleblower system

Anonymity

In order to ensure your anonymity, we have commissioned the wvib to anonymize the reports. We receive your complaints without any contact details.

What can be reported?

You can use the reporting system to report violations of our Code of Conduct or violations of the law. Including issues related to bribery and corruption, competition law, fraud, financial crime, product safety and quality, harassment or discrimination, international trade controls, the protection of personal data, rights and protection of persons, serious environmental damage or conflicts of interest.

Content of the report

In order to be able to handle your report as precisely as possible, we would like to ask you to include the following information in your email:

Reason for the report
Are you an employee of the affected division?
Affected department of the report
Persons involved
Location of the report

FAQ

Source: 2023-09-01_FAQs_Hinweisgeber.pdf (wvib.de)

Who can submit information via the reporting channels presented at www.wvib.de?

The reporting channels of the joint internal whistleblowing service (hereinafter: “whistleblowing service”) of the trade association of industrial companies in Baden (Wirtschaftverband Industrieller Unternehmen Baden e. V. – hereinafter: “wvib”) are open to all employees* of wvib member companies participating in the wvib whistleblower service. If your employer participates in the wvib whistleblower service, this should have been communicated company-wide. In this context, employees also include temporary workers, agency staff or job applicants.

What can be reported through these reporting channels?

Information about violations that you have become aware of in connection with your professional activities – including the application process – may be reported through the reporting channels. Any behavior that is subject to criminal penalties is considered a violation. This includes violations of the Criminal Code as well as violations of other laws that contain penal provisions, such as the Anti-Corruption Act. Likewise, behavior subject to a fine is covered if the violated regulation serves to protect life, limb or health or to protect the rights of employees or their representative bodies. Examples of this are the Working Hours Act or the Minimum Wage Act. Furthermore, a catalog of violations of (EU) legal provisions is covered, which is listed in full in Section 2 (1) no. 3 HinSchG.

What specific reporting channels are there?

You can submit information via the three reporting channels that have currently been set up. These are:

E-mail (hinweis@wvib.de)
Phone (0761 / 4567 – 444)
Letter (Wirtschaftsverband Industrieller Unternehmen Baden e.V., Keyword: HINWEIS, Merzhauser Straße 118, 79100 Freiburg i.Br.)

At your request, a personal meeting can also be arranged with the wvib lawyer in charge of the reporting office, subject to time constraints, during wvib’s normal business hours (weekdays from 9:00 a.m. to 5:00 p.m.) and on wvib’s premises. Likewise, a video call can be arranged at your request.

Am I allowed to include trade secrets and/or confidential company information in my report?

Trade secrets and confidential information must always be kept strictly secret. However, if you have sufficient reason to believe that the information regarding the violation you have reported is true and that disclosing the content of this information is necessary to uncover the reported violation, which is within the scope of the HinSchG (see § 2 HinSchG), then in this special case it is permitted to disclose trade secrets or confidential information to the reporting office.

Can anonymous reports be submitted?

Anonymous reports should not be submitted via the whistleblower channels. The reason for this is that it is not possible to ask you any follow-up questions. In the event that an anonymous report is received, wvib’s lawyers will process the information to the extent possible. However, in this case it is not possible to send an acknowledgement of receipt or a notification of the follow-up measures taken under the HinSchG.

What protection is provided to a whistleblower?

Your personal data will be treated confidentially by the reporting office. This means that, for example, your name or position in the company will never be passed on to the relevant employer without your express consent. Since it cannot be ruled out that the content of a report may allow conclusions to be drawn about you, you as a whistleblower also enjoy extensive protection against reprisals. This means that you may not suffer any disadvantages as a result of the report you have submitted. This includes the threat and attempt of reprisals. On the other hand, grossly negligent or even intentional false reports are not protected.

What are the consequences of making a false report?

If you intentionally or negligently report incorrect information to the reporting office, you may be liable for damages to any injured party or company (see § 38 HinSchG). In addition, there may be consequences under labor law on the part of your employer.

What happens to my personal data?

Your personal data will be processed by the reporting office. The data will only be passed on to third parties if it is necessary to notify you of follow-up measures and only if you have given your express prior consent to the data being passed on. The HinSchG stipulates a retention period of three years. After the three-year period has expired, your personal data will be deleted. Further information on the processing of your personal data can be found in the document “Data protection information for reporting via the reporting channels” on the website https://www.wvib.de/Pages/Hinweisgeberschutz.aspx.

What happens after a report has been submitted?

After the reporting office has received your report, wvib’s lawyers will conduct a preliminary review. This preliminary review includes the plausibility of the information provided and the question of whether the information reported concerns an infringement as described in Section 2 of these FAQs. If the preliminary review is positive, the reporting office will forward the report to the company concerned. It is then up to the company to take measures to stop the reported violation. If the preliminary review concludes that no appropriate measures can be taken within the company to stop the violation, the report can also be forwarded to a competent authority. You will receive a confirmation of receipt within seven days of the report being received by the reporting office. You will be informed of the follow-up action taken in your individual case no later than three months after the confirmation of receipt.

Compliance

Declaration of Human Rights Principles

Business Partner Code

Whistleblower system

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