Compliance
whistleblower
system
Our whistleblower system enables all persons to report information anonymously and without risk of personal consequences. The whistleblower system is provided by the external provider otris software AG. The protection of whistleblowers is our top priority. We have therefore taken measures to ensure that this protection is also provided by our external provider.
Procedure
1. reporting violations
Employees and third parties in the operational context of Heimathafen Hotels can report violations of applicable laws, legal provisions and the company's own guidelines, procedures or work instructions via our integrated whistleblower system.
2 Confirmation of the report
Once you have submitted the report, you will receive confirmation of receipt within 7 days. With the help of a whistleblower ID and the password you have defined, you can check the status and traceability of your whistleblowing report on the reporting platform while maintaining your anonymity.
3. review and investigation
Incoming reports are checked for validity by our internal reporting centre and, if necessary, further investigations are initiated and measures taken on this basis. After completion of the procedure, at the latest 3 months after confirmation of receipt, you will receive notification of the outcome of the procedure, which you can access using your PIN.
4 Consent to the disclosure of information, if applicable
In some cases, it may be necessary to pass on your information in order to take follow-up measures. We generally require your consent for this. Heimathafen Hotels observes the prohibition of reprisals against whistleblowers at all times.
Access to the reporting platform
The following link will take you to the reporting platform where you can anonymously report information and offences.
Principles of the whistleblower system
Anonymity
You can submit your report anonymously. Personal data is optional and will only be used by the internal reporting centre for substantive investigation. If further measures are taken that could reveal or infer your identity, we require your written consent to pass on your information.
Voluntariness
All notifications are made on a voluntary basis. Providing your name is optional and not mandatory. If you wish to forward your report to Heimathafen Hotels, we will ask for your
consent to the use of personal data will be requested.
Freedom from sanctions
Whistleblowers do not face any sanctions. We make sure that no reprisals are taken against whistleblowers.
Independence
The internal reporting centre works independently of official instructions from Heimathafen Hotels.
Confidentiality
Personal data will not be passed on to third parties. All reports and associated investigations are treated confidentially. Those involved are obliged to maintain confidentiality. This obligation also applies after termination of their function. We require your written consent to pass on your information for measures that allow your identity to be disclosed or inferred.
Further options for submitting information
In addition to the aforementioned digital reporting platform via the external provider, there are other reporting channels available.
Of course, our principles of the whistleblowing system also apply to these reporting channels.
Submitting reports by telephone via the dedicated telephone service: 0451 160852-15
Report by letter to:
Herold Unternehmensberatung GmbH
Philipp Herold - Confidential / Compliance
Hafenstraße 1a
23568 Lübeck
