Rules of procedure compliance helpline

These rules of procedure apply to all information received on the compliance helpline, except for complaints from customers or business partners regarding disruptions to their business relationship, for which the respective customer service department is particularly responsible.

Information can be submitted either by employees or by external third parties, particularly by people who have potentially been affected.

The compliance helpline is overseen by the following external ombudsperson:

Prof. Dr. Eva Kohler
Ruhrtal 5
58456 Witten, Germany

The compliance helpline can be reached via the following reporting channels, which are free of charge for those submitting a report:

The protected and encrypted contact form on this page
By e-mail at kohler@helpline-werhahn.de
By telephone: 00800 17 17 17 17 (available internationally)

Special phone numbers apply to the following countries:

India: 000800 049 0030
Japan: 010 800 17 17 17 17
Japan: 0033 010800 17 17 17 17 (from other networks via NTT)
Japan: 001 010800 17 17 17 17 (from other networks via KDDI)
Japan: 0061 010800 17 17 17 17 (from other networks via Softbank)
Canada: 011800 17 17 17 17
Russia: 810 800 17 17 17 17
Turkey: 00800 491 17 17 17 17
Ukraine: 0800 503998
USA: 1 833 209 6531

Information can also be submitted to the compliance officer of the respective company concerned. These rules of procedure apply accordingly to such reports.

In the event of a report, the process is divided into the following procedural steps:

| A. | Confirmation of receipt
| B. | Recording of the reported matter
| C. | Explanation of the procedure
| D. | Confidentiality, ban on reprisals
| E. | Documentation
| F. | Further procedure, follow-up measures
| G. | Corrective measures
| H. | Response
| I. | Deletion periods

A. Confirmation of receipt

The confirmation of receipt usually takes place via the same reporting method chosen by the person submitting the report. For a report via a voice message, the confirmation takes place via the contact method stated by the reporting person.

The confirmation of receipt takes place within seven days.

If a report is submitted anonymously and without providing contact details or if no secure inbox was set up for the submission of anonymous information via the compliance helpline portal, the confirmation of receipt cannot be provided.

B. Recording of the reported matter

The ombudsperson records the matter reported by the reporting person as precisely as possible. They discuss the matter with the reporting person, if a contact method exists, and make the necessary enquiries to determine, in particular, the following information:

What happened?
When did it happen and does the situation still persist?
Where did it happen? At which company and at which site?
Who is affected?
Is there any evidence or proof?

C. Explanation of the procedure

The ombudsperson explains to the reporting person the procedure that follows a report. The measures to ensure confidentiality and the ban on reprisals are also explained.

D. Confidentiality, ban on reprisals

The confidentiality of the identity of the reporting person, the persons who are the subject of the report, and other persons mentioned in the report is ensured by the compliance helpline according to the legal requirements. The identity of the stated persons may exclusively be known to the persons who are responsible for receiving reports or for implementing follow-up measures, as well as the persons that assist them in fulfilling these tasks. Any exceptions from this arise from the respective applicable legal provisions.

Due to their rights according to these rules of procedure, in particular the right to make a report, reporting persons may not be disadvantaged if they had sufficient reason to assume that the information they reported corresponded to the truth. Reprisals against reporting persons are prohibited. This also applies to the threat of and attempt to take reprisals. The ombudsperson will investigate any reports of disadvantages from the reporting person and clarify whether there is a correlation between the report and the disadvantage. If this should be the case, the ombudsperson, together with the compliance officer from the respective company, will arrange for an immediate remedy.

E. Documentation

The ombudsperson documents the report according to the legal requirements, particularly while respecting the confidentiality requirement.

For reports that are not received in writing or in text form, the following applies:

I. Phone call or voice message
For telephone reports or reports via another type of voice communication, a permanently accessible audio recording of the conversation or its complete and precise transcript (verbatim record) may only be made with the consent of the reporting person. If such consent does not exist, the report is documented with a summary of its content (content record).

II. Personal meeting
The ombudsperson documents the conversation with a content record.

The ombudsperson can produce a permanently accessible audio recording or a verbatim record of the phone call or personal meeting instead of a content record if the reporting person consents to this. The consent is to be documented. If the ombudsperson has used an audio recording to produce a verbatim record, they will delete the audio recording as soon as the record has been completed.

Where records are produced, the reporting person is always given an opportunity to check the record, correct it if necessary, and confirm it with their signature or in electronic form.

F. Further procedure, follow-up measures

The ombudsperson forwards the report to the persons responsible for its further processing within the company concerned by the report and, in the event of significant importance, also to the responsible persons at Wilh. Werhahn KG. These are primarily the responsible compliance officers. They may bring in other responsible persons, such as data protection officers or human rights officers.

The responsible persons decide on the initiation of follow-up measures. These include, in particular:

Performance of internal investigations including enlisting third-party experts for a further investigation
Referral of the reporting person to a responsible body
Submission of the procedure to a competent authority
Conclusion of the procedure due to a lack of evidence or for other reasons
Corrective measures

G. Corrective measures

The compliance officer of the company concerned by the report identifies the necessary corrective measures if a complaint proves to be justified and initiates the implementation of these measures in a timely manner. They inform the external ombudsperson of this.

H. Response

The ombudsperson provides the reporting person with a response corresponding to the legal requirements concerning the follow-up and possible corrective measures

within three months of the confirmation of receipt of the report or,
if the receipt was not confirmed, at the latest three months and seven days after the receipt of the report

following consultation with the responsible compliance officers.

A response may only be provided to the reporting person to the extent to which internal enquiries or investigations are not affected and the rights of the persons who are the subject of a report or are stated in the report are not infringed upon.

I. Deletion periods

The ombudsperson oversees compliance with the legal deletion periods for the documentation. Otherwise, the documentation is deleted if there is no further legitimate interest in its retention.

If a deletion is pending, the ombudsperson informs in advance the persons involved with processing within the Werhahn corporate group at the time and deletes the documents stored by them when the period expires.

Alongside documentation (E.), the ombudsperson records the received report with no reference to persons for statistical purposes. This data collection, which is anonymised in every regard, is not subject to any deletion periods.