Ethics and Integrity Reporting

What reporting channels are available to you in your situation?

You are considering submitting your report via Otris, our compliance reporting portal. This is a good option, especially if you wish to remain anonymous. Alternatively, I would be happy to offer you a personal conversation on a confidential basis. You can reach me at [ OFFICE PHONE / Compliance Coordinator] or on my cell phone at [ CELL PHONE ]. During such a conversation, we could also first discuss in more detail any questions you may have about whether and how to file a report, as well as the subsequent process.

How do we handle reports?

Reports submitted through the Otris reporting portal are accessible only to a select few employees in the Compliance, Legal, and Internal Audit departments. The Compliance department first reviews the report and categorizes it according to subject matter. All issues involving misconduct or serious wrongdoing are either investigated by us directly, referred to the appropriate department, or closely monitored. We ensure discretion throughout this process. The number of people involved is kept as small as possible.

In particular, no one is involved in the process who

– is potentially implicated in the matter,

– is presumed not to be neutral or even has an interest in influencing the outcome of the investigation, or

– whom we fear might subject the reporting individual to negative consequences.

What happens after you submit your report?
  • Your report will be reviewed confidentially by trained compliance officers.
  • An investigation will be conducted, depending on the matter, which may involve reviewing available documents, interviewing witnesses, and/or seeking support from other internal or external specialized functions. These may include individuals who have knowledge of the facts, understand the subject matter, and can thus help clarify the facts of the case.
  • We conduct our investigation neutrally, meaning that all facts and circumstances are considered impartially.
  • Once we have conducted a sufficient investigation, we perform an objective assessment of the findings:
  • * If the allegations are substantiated, appropriate measures are developed to remedy the reported issue. These may include personnel or organizational measures, changes to workflows, or awareness/training initiatives, etc. As a company, we can only continuously improve if we effectively address problems!
  • * If no evidence is found to support the report, the investigation will be closed.
  • In accordance with legal requirements, whistleblowers will be informed at a minimum of the start and conclusion of the investigation. We strive for the greatest possible transparency. However, the level of detail in our feedback to whistleblowers depends heavily on the specific case.
How anonymous is “anonymous”?

Your report will be handled with the utmost care and confidentiality. If you choose to submit an anonymous report, your identity will not be determined or disclosed. The reporting portal and our process are designed to protect your anonymity—unless you yourself wish to be contacted personally.

I would like to encourage you to do so, as direct communication between us facilitates our interaction. This is often crucial to the success of the investigation.

If you decide to remain anonymous, you can view and respond to any feedback or follow-up questions I send via your anonymous mailbox in Otris.

Whistleblower Protection

Whistleblower protection is enshrined in law (e.g., through the Whistleblower Protection Act) and is actively implemented by us. No one may be disadvantaged or pressured because of a report if it is made in good faith and with confidence in the accuracy of the circumstances described. Importantly, no excessive requirements are imposed here: your sincere suspicion is sufficient!

The safety and trust of our whistleblowers are our top priority.

Additional Sources of Information

You can also find additional information in the FAQs on the reporting platform and in our OC Code of Conduct. Section VI.3. (page 10) of the Code contains the relevant provisions regarding complaints and reports. You may also find guidance in the Code on how to classify your specific situation.

I hope this message has answered your questions so that you can decide to place your trust in us. We are here for you and take your reports seriously.