The Zumtobel Group’s whistleblower system
The Zumtobel Group’s whistleblower system
The Zumtobel Group’s whistleblower system provides all stakeholders (employees, sup- pliers, value chain workers, consumers and end-users, shareholders, investors, etc.) with a secure system to report and communicate potential violations of the Code of Conduct and compliance issues, such as suspected corruption or bribery. Critical concerns and issues are therefore reported directly to Cor- porate Audit and Compliance. Reports can also be submitted by email, as an additional communication channel. The independence of the Zumtobel Group’s Compliance department ensures that cases are processed independently of the management chain. Reported incidents are processed in line with the internal investi- gation guidelines, which provide clear, stan- dardised procedures for the submission, investigation, follow-up and closing of cases. Corresponding actions are then derived as required. All applicable reports received are communicated to the Management Board. The Management Board is informed of any reports involving risk without undue delay. Reports that do not present a mate- rial risk are submitted as part of the quar- terly reporting. Where there is no need to immediately inform the Audit Committee of any violations, they will be communicated in the quarterly reports submitted to the Audit Committee. Individuals can contact Corporate Complian- ce regarding any issues related to responsi- ble business conduct in the organisation’s operations and business relationships through a number of channels. The relevant information is accessible on the Group’s intranet for all employees. This option is regularly used in practice.
Several channels are available for internal and all external stakeholders to raise con- cerns, including a confidential whistleblower hotline. Technical support for the Zumtobel Group’s whistleblower system is provided by the Integrity Line (EQS). The whistleblower system complies with all legal requirements of the EU Whistleblower Directive and the Whistleblower Protection Act as per Direc- tive (EU) 2019/1937. The Zumtobel Group’s whistleblower system gives all employees and external third parties around the globe the opportunity to report anonymous tips about suspected violations using a link on the Zumtobel Group’s homepage. The defined reporting priorities are described in the next section. The whistleblower system is overseen by Corporate Compliance and ensures that reports received are promptly classified and processed. The identity of the whistleblower is always treated confidenti- ally, impartially and objectively. No form of retaliation is tolerated. As one of the basic requirements of the EU Whistleblower Direc- tive that came into force on 16 December 2019 and its transposition into national law, confidentiality of the whistleblower’s identity is always guaranteed.
Prevention and detection of corruption and bribery [G1-3]
The Corporate Audit department regularly reviews procurement processes. In terms of corruption, the following aspects in parti- cular are reviewed: selection of suppliers, number of suppliers approached and the associated process, decisions regarding suppliers, contractual arrangements, pay- ment terms, price trends, supplier quality monitoring and the resulting actions. When a contract is being concluded with external partners, reference is made to the whistle- blower policy in the Code of Conduct, which all potential partners are required to sign.
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