The whistleblower system is part of the compliance culture at Klüh Service Management GmbH (hereinafter referred to as Klüh). Generally speaking, compliance means more than the company just acting in accordance with the law.
At Klüh, compliance is about doing the right thing. Our objective is to operate in accordance with ethical principles as well as to comply with all rules and regulations.
We have started to build risk-based compliance management systems aligned with the business activities of each of our divisions. We are convinced that compliance safeguards what is most important to us: the well-being of our employees and of the clients to whom we provide services.
Compliance is anchored in our corporate culture and guides us in our day-to-day work. Integrity, responsibility and reliability are at the core of our understanding of compliance. It also includes proper and lawful conduct, which is a top priority for Klüh.
Moreover, our corporate success is based on integrity and legal compliance. In order to achieve this aspiration, it is important that we identify and remedy any potential misconduct at an early stage. Against this backdrop, we have established our whistleblower system. This helps to identify and investigate any operational concerns, conduct that could harm the company or economic crime and protect our employees, business partners and clients.
We take all reports you make seriously and process them systematically. One cornerstone of Klüh’s whistleblower system is the principle of fair process. We also guarantee maximum protection for whistleblowers, the subjects of reports and all employees involved in processing reports. We will not tolerate any pressure on whistleblowers and the people who contribute to promoting proper conduct at Klüh.
The subjects of reports are presumed to be innocent until any breach of compliance is proven. Investigations shall be conducted in the strictest confidence. The information received will be used in a fast, fair and confidential process.
Do you have a concern or feedback about a service provided by Klüh?
If you have any questions, feedback or complaints about one of Klüh’s services, please send these to Customer Support at info@klueh.de.
The whistleblower system is not intended for accepting and processing customer concerns and, in particular, will not forward these within our organisation. Customer Support will be pleased to review your concern and take any measures necessary to ensure your satisfaction.
Do you want to report a breach of data protection regulations?
If you want to report a breach of data protection regulations, please send an e-mail to datenschutz@klueh.de.
This is how you report potential misconduct.
To ensure that your report can be properly processed and investigated by our Compliance Team, it is important that you are as specific as possible.
It will help us if you use the following five questions to guide you: Who? What? When? How? Where?
All whistleblowers are encouraged to provide their contact details in reporting any concerns, misconduct, hazards, etc. openly and directly. Generally speaking, internal risk communication should not be anonymous as this prevents any further questions being asked and may have a negative impact on trust. Anonymous reports should therefore be the exception.
Every report should be as specific as possible. Whistleblowers should provide as much detailed information as possible about the subject of the report so that the issue can be correctly assessed. In this connection, the background, course of events and reason for the report should be given as well as names, dates, places and other information. If available, documents should also be submitted. Personal experiences, possible bias and subjective opinions should be identified as such.
Each report will be treated in confidence and in compliance with valid data protection legislation. When a report is received, the person who receives the report makes an initial assessment. In particular, it is important to identify whether there is any evidence that supports or rebuts the information provided.
The contact at Klüh is the Compliance Officer, to whom all reports should be addressed.
Central e-mail address: compliance@klueh.de
The Supply Chain Due Diligence Act
With the introduction of the Supply Chain Due Diligence Act (German: Lieferkettensorgfaltspflichtengesetz, abbreviated as LkSG in the following), the legislator has created the framework conditions for responsible and sustainable value creation along the entire supply chain.
We at Klüh fulfil the requirements of the LkSG. We have set up an appropriate central risk management system and carry out regular analyses in order to identify and minimise potential human rights and environmental risks and to prevent, end or minimise the extent of any violations of human rights or environmental obligations.
With the help of appropriate preventive measures, we also prevent human rights and environmental risks in our own business area or at suppliers.
The complaints procedure
We have set up a complaints procedure to ensure that the LkSG is complied with in our own business area and in the supply chain. Information on human rights and environmental risks and violations can be submitted there. The rules of procedure for the complaints procedure can be found here.
Klüh has decided to set up a centralised whistleblowing system at its Group holding company. This can be reached by email at compliance@klueh.de.
Responsibility
The Klüh Compliance Team is responsible for the content of this page. It can also be contacted at compliance@klueh.de.
12th July 2024
