Sustainable business practices form the basis for the future prospects for the environment, society and economy, as well as for every single employee or business partner of KP Family International GmbH .
The cornerstone of the corporate culture is a common understanding of values and risk minimization for sustainable corporate development.
The whistleblower system with legal expertise of the Ratisbona Compliance GmbH (“RC-Whistle”) creates additional trust and security through a clearly defined structure accessible to everyone and a legally sound initial assessment in order to point out grievances and thus ensure the sustainable success of KP Family International GmbH and avert damage.
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WHISTLEBLOWING POLICY
1. POLICY
Sustainable business practices form the basis for the future prospects for the environment, society and economy, as well as for every single employee or business partner of KP Family International GmbH .
The cornerstones of the corporate culture are the allocation of central requirements and their independent implementation and management in the subsidiaries as well as a common understanding of values and risk minimization for sustainable corporate development.
The whistleblower system with legal expertise from Ratisbona Compliance (“RC-Whistle”) creates additional trust and security through a clearly defined structure accessible to everyone and the legally sound initial assessment to point out grievances and thus the sustainable success of KP Family International GmbH to secure and avert damage.
2. SCOPE
a) This policy describes the procedure for reporting confirmed or suspected grievances or misconduct.
b) It applies to all employees (including temporary workers), customers, suppliers and anyone who has an interest in the well-being of society.
3. KNOWLEDGE OR REASONABLE SUSPICION OF AN IMPROPER CONDITION
a) We want every employee encourage anyone who has knowledge or reasonable suspicion of significant misconduct (violation of the law or unethical behavior contrary to our Code of Conduct) to report it.
b) We encourage every employee to report such issues through the known and established reporting channels. These include (for example):
i) confidant
ii) Human resources
iii) Works council
iv) Management
v) Internal suggestion and reporting system
vi) Compliance area
c) If none of these reporting channels are suitable for your report, you can use the whistleblower system with legal expertise from Ratisbona Compliance . Ratisbona Compliance 's whistleblower system is operated by an independent third party.
d) Ratisbona Compliance 's legal expertise, reports are submitted directly to Ratisbona Compliance . Reports can be submitted digitally via the Ratisbona Compliance reporting platform, by phone, or in person.
4. INTENTIONAL FALSE REPORTS
Intentional false reports will be considered a violation of the Code of Conduct and treated accordingly. They may result in disciplinary action and/or criminal prosecution.
5. ASSIGNMENT OF RESPONSIBILITIES
a) Ratisbona Compliance 's whistleblower system enables anonymous communication with whistleblowers and, if necessary, ensures confidentiality. Upon receipt of a report of alleged misconduct or fraudulent behavior, the matter is subjected to an initial review based on the information provided.
b) Ratisbona Compliance is responsible for the timely review and processing of incoming reports.
c) Further inquiries to the whistleblower for further assessment of the facts are possible while maintaining anonymity.
d) Based on this initial review, the next steps in dealing with the matter are determined. Depending on the severity of the allegation, the group of individuals affected, and the legal area, the report is forwarded to the responsible department of the respective investment or group of investments. External experts may be consulted for further investigation of the irregularity. A reporting obligation may arise if there is sufficient suspicion of a criminal offense. Ratisbona Compliance ensures that all reported cases are investigated and concluded with adequate documentation.
e) KP Family International GmbH expects managers and supervisors at all levels of the hierarchy to take such reports seriously, treat them with the strictest confidentiality and to promptly clarify them with the appropriate guidelines and necessary measures in order to eliminate the grievance.
6. NO FOLLOW-UP OF A REPORT
Ratisbona Compliance may decide not to pursue a report further, for example if
a) there is insufficient information available for an adequate investigation and there is no possibility of obtaining further information
b) the report is proven to be false.
7. REPORTING
Reporting is carried out by the Legal Department of Ratisbona Compliance. Reporting is detailed for cases investigated by Ratisbona Compliance .
8. PROTECTION AND RIGHTS OF THE REPORTER
a) The identity of all reporters will be treated with absolute confidentiality. Ratisbona Compliance will not disclose voicemails, IP addresses, and/or phone numbers under any circumstances, unless "8c" applies.
b) No one who submits a report has to fear negative consequences. However, even those who report (as whistleblowers) are not protected against misconduct.
c) In the following cases, the protection of the reporter is not guaranteed:
i) Upon request, for example from law enforcement authorities, Ratisbona Compliance is obliged to provide voice messages, IP addresses and/or telephone numbers.
ii) Cases where it was found that reports were made intentionally false or against better knowledge and/or in bad faith;
iii) or if the report itself must be classified as a criminal offense or a violation of the Code of Conduct (e.g. defamation or threats).
d) If the reporting party does not agree with the result of the investigation, he or she has the opportunity to do so again via the whistleblower system with legal expertise from Ratisbona Compliance to make known .
9. PROTECTION AND RIGHTS OF ACCUSED PERSONS
a) If an investigation is initiated based on a report, KP Family International GmbH will inform those affected within 30 working days at the latest. This period may be extended depending on the specific circumstances of the case, e.g., if there is a risk that evidence will be destroyed or the initiated investigations will be otherwise hindered.
b) Those affected have the right to complain about investigations directed against them. To do so, they should contact:
i) Your supervisor or managing director
ii) Ratisbona Compliance contact information can be found at the end of this policy.
10. DATA PROTECTION
Ratisbona Compliance will treat all information with the strictest confidence. The protection of the data of both the reporting party and the affected parties is guaranteed within the legal framework. Information is made accessible on a limited basis, both in terms of content and the target group (so-called "need- to - know " basis). This policy requires the processing and storage of personal data. This occurs exclusively in accordance with data protection regulations.
Only the German version of this guideline is legally valid.
Ratisbona Compliance GmbH
Ostengasse 14
93047 Regensburg
T +49 941 2060384-1
M info@ratisbona-compliance.de
www.ratisbona-compliance.de
