Compliance
Whistleblowing
Scheme
Our whistleblowing system enables anyone to report concerns anonymously and without risk of personal repercussions. The whistleblowing system is provided by the external service provider otris software AG. The protection of whistleblowers is our top priority. We have therefore taken measures to ensure that this protection is also guaranteed by our external service provider.
Procedure
1. Reporting breaches
Employees and third parties within the business context of Heimathafen Hotels can report breaches of applicable laws, regulations and the company’s own policies, procedures or work instructions via our integrated whistleblowing system.
2. Confirmation of the report
Once you have submitted your report, you will receive confirmation of receipt within 7 days. Using a report ID and the password you have set, you can check the status and track the progress of your report on the reporting platform, whilst your anonymity is preserved.
3. Review and investigation
Reports received are assessed by our internal reporting office to determine their validity; based on this, further investigations may be initiated and measures taken where appropriate. Once the process has been completed – no later than 3 months after the acknowledgement of receipt – you will receive a notification regarding the outcome of the process, which you can access using your PIN.
4. Consent to the disclosure of information, where applicable
In some cases, it may be necessary to disclose your information in order to take follow-up action. We generally require your consent for this. Heimathafen Hotels strictly observe the prohibition on reprisals against whistleblowers at all times.
Access to the reporting platform
The following link will take you to the reporting platform, where you can report concerns and breaches anonymously.
Principles of the whistleblowing system
Anonymity
You can submit your report anonymously. Personal data is optional and will only be used by the internal reporting office to carry out a thorough investigation. Should further action be taken that could result in the disclosure of your identity or allow it to be deduced, we will require your written consent to pass on your information.
Voluntary participation
All reports are made on a voluntary basis. Providing your name is optional and not compulsory. If you wish to forward your report to Heimathafen Hotels, you will be
consent to the use of personal data.
Protection from sanctions
Whistleblowers face no sanctions whatsoever. We ensure that no reprisals are taken against whistleblowers.
Independence
The internal reporting office operates independently of any official instructions from Heimathafen Hotels.
Confidentiality
Personal data will not be disclosed to third parties. All reports and any associated investigations are treated confidentially. Those involved are bound by a duty of confidentiality. This obligation remains in force even after they have left their post. In the event of any measures that could lead to the disclosure of, or allow inferences to be drawn about, your identity, we require your written consent to pass on your information.
Further options for submitting reports
In addition to the aforementioned digital reporting platform provided by the external service provider, other reporting channels are available.
Naturally, our whistleblowing system’s principles also apply to these reporting channels.
Submitting a report by telephone via the dedicated telephone service: 0451 160852-15
Submitting a report by post to:
Herold Unternehmensberatung GmbH
Philipp Herold – Confidential / Compliance
Hafenstraße 1a
23568 Lübeck
