Corporate Compliance
The WMF Group’s corporate culture is characterised by clear responsibility, mutual respect and trust in our business partners and employees. However, this does not rule out the risk of infringement of the law and/or individual misconduct with absolute certainty.
The WMF Group strives to minimise these risks. A compliance organisation and a global ombudsman system has been set up for this purpose. Both employees and third parties (customers, suppliers, etc.) can confidentially and – upon request – anonymously contact an external, independent lawyer should they have any information about economic offences, infringements of anti-trust law or breaches of internal guidelines, for example. His contact details are as follows:
Lawyer Dr. Carsten Thiel von Herff, LL.M.
Loebellstraße 4
33602 Bielefeld
Germany
Freephone: 00800 “OMBUDSMANN” = 00800 6628376266
Calls made to the 00800 number are free for callers based in the following countries: Austria, Belgium, China, the Czech Republic, France, Germany, Italy, Japan, the Netherlands, Singapore, Spain, Switzerland, the UK and the USA.
The designated lawyer can also be anonymously contacted through “commUNITYcate”, the WMF Group’s certified compliance whistleblower system. In offering this system, we are providing all of the WMF Group’s employees and business partners with a protected and confidential channel for reporting compliance breaches:
External reporting channels
Grievances and irregularities can be reported to an external reporting office rather than the internal office. The law provides whistleblowers with a right to choose in Section 7 (1) sentence 1 of the Whistleblower Protection Act (HinSchG). According to Section 7(1) sentence 2 HinSchG, whistleblowers should give preference to filing a report to an internal reporting office in cases where effective internal action can be taken against the violation and they do not fear reprisals.
External federal reporting office
In addition to internal reporting, the law provides for the option of filing a report externally. For this purpose, the federal government has set up the federal external reporting office at the Federal Office of Justice (BfJ). The reporting channels that whistleblowers can use to contact the federal external reporting office have been published on the BfJ website since 2 July 2023. Further information on the BfJ’s external reporting office can be found here:
https://www.bundesjustizamt.de/hinweisgeberstelle.html?nn=13736
In addition to the federal external reporting office at the BfJ, the existing reporting systems at the Federal Financial Supervisory Authority (BaFin) and the Federal Cartel Office will continue to exist for their specific areas of responsibility. Please also read the information on the websites of these reporting offices/whistleblowing offices:
www.bafin.de
www.bundeskartellamt.de
Information on procedures for filing reports to offices of the European Union (EU)
In addition to information on external reporting procedures according to the HinSchG, the specifics on the procedures for filing reports to EU bodies, institutions or other offices can be found via the following links. These include external reporting channels to the Commission, the European Anti-Fraud Office (OLAF), the European Maritime Safety Agency (EMSA), the European Aviation Safety Agency (EASA), the European Securities and Markets Authority (ESMA) and the European Medicines Agency (EMA).
OLAF: https://anti-fraud.ec.europa.eu/index_de
EMSA: https://www.emsa.europa.eu/de
EASA: https://www.easa.europa.eu/en
ESMA: https://www.esma.europa.eu/
EMA: https://www.ema.europa.eu/en.
The reporting procedures there are unaffected by the HinSchG, i.e. they will continue to exist unchanged alongside the internal and external reporting procedures according to the HinSchG.
Further information on external reporting offices and procedures of the EU
Further information on external reporting procedures and relevant reporting procedures of bodies, institutions and offices of the European Union can be found on the BfJ website and accessed here:https://www.bundesjustizamt.de/DE/MeldestelledesBundes/Fragen/Fragen_node.html#AnchorDocument96692