The whistleblower system is open to all internal and former employees as well as contractors, subcontractors and their suppliers and other stakeholders.

Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting infringements of Union law and the national Whistleblowing Act (WbG) provide in particular for infringements of public procurement, financial services, product safety and conformity, environmental protection, consumer protection, but also the protection of personal data and the security of network and information systems as reportable. Conduct that is contrary to the interests of the company, such as fraud, corruption or self-dealing, is therefore just as reportable as conduct that is directed against the violation of human rights or environmental protection.

Hueck Folien also permits the reporting of violations of the company's internal code of conduct if these violations are likely to cause significant damage to the company.

Significant damage is, for example, associated with the commission of a criminal offense, but damage to the company's reputation can also mean significant damage.

Cases of customer complaints may not be reported in the whistleblower system. These must continue to be submitted via the familiar reporting channels such as customer service and complaints management.

Cases that are exclusively in the company's own interest cannot be reported either.

The introduction of the whistleblower system harbors the risk that this instrument may be used to denounce or vilify other persons with reported information without cause and without verification, thus bringing them into disrepute.

The information described above is exclusively in the company's own interest and does not reveal any internal misconduct or illegal behavior within the meaning of the EU Directive or the applicable Code of Conduct. They may therefore not be reported via the whistleblower system.

Information about suspected legal violations must be reported via the digital whistleblower system introduced by Hueck Folien GmbH.

 

Information via the digital whistleblower system

In cooperation with the software provider Akarion, Hueck Folien has introduced a digital whistleblower system that enables external and internal whistleblowers to submit a report either anonymously or by name.

Within Hueck Folien, an internal reporting office (whistleblower office: human resources management) has been set up, including deputy regulations (head of quality management). The whistleblower office receives the information for examination. These are processed within a closed IT-supported system to which only the Whistleblower Office has access and insight. Access by unauthorized third parties is thus excluded.

There are two buttons on the start page of the whistleblowing tool.

Selecting the "Report" button starts a new reporting process that involves several steps.

First, the incident itself must be described. It is possible to verify or substantiate the tip by uploading documents and photos. Some fields, such as the incident description and the incident date, are defined as mandatory fields that must be filled out and marked with an *. Additional information can then be provided in subsequent optional fields.

In the course of the reporting process, you can decide whether you want to submit the information by name or anonymously. In the case of a named tip, this will only become visible to the whistleblower office and will not be accessible to any other persons. Your personal data will only be processed within the framework described in our data protection declaration.

After your confirmation that you have submitted your information to the best of your knowledge and in good faith, the information can be sent.

When you send the report, it is recorded in the system and a separate mailbox is set up for you as a whistleblower. As a whistleblower, you will then receive a report ID and a password that will enable you to access your mailbox at any time and to contact the whistleblowing office. The access data is known only to you. Therefore, keep them carefully until the processing of your whistleblowing is completed. Access to your mailbox by third parties is excluded.

 

LogIn

By using the log-in data sent to you after submitting your report, you can call up the status of the procedure at any time and contact the Whistleblower Unit to supplement or correct your report at any time.

The report is received within the whistleblowing system. As a whistleblower, you will receive a standardised confirmation of receipt immediately after receipt of the report. Within three months after the confirmation of receipt, you will receive qualified feedback regarding the status of the procedure or any follow-up measures taken.

By using your individual ID, you can actively register in the whistleblower system, stay informed about the status of the procedure and contact the whistleblower unit as well as answer any queries.

You as a whistleblower receive special protection based on the legal framework mentioned above.

owever, this protection is only granted to you if, at the time of the reporting, you had reasonable grounds to believe, based on the factual circumstances of the information available to you, that the information you provided is true and falls within the scope of the legal provisions concerning whistleblowing. Your identity, your report and your communication with the Whistleblower Unit will remain strictly confidential and will be protected by appropriate technical and organisational measures in the system used.

Evidently false or misleading information will be rejected by the Whistleblower Unit. If necessary, they may give rise to claims for damages or be prosecuted in court or as an administrative offence.