Whistleblower system

Questions & Answers about the Ombudsman's Office, the Complaints Procedure under the Supply Chain Due Diligence Act, and the Internet-Based Whistleblower System at The Quality Group GmbH and its subsidiaries (“TQGG”)

What is an Ombudsman's Office / Complaints Office (“Whistleblower System”)?

In order to combat violations of legal regulations and/or internal compliance rules, as well as violations of human rights and environmental due diligence obligations, TQGG has appointed an external lawyer as Ombudsman and contact person for our Whistleblower System. The Ombudsman is available to all whistleblowers who wish to provide confidential information about irregularities at TQGG.

Who can contact the Whistleblower System?

Our Whistleblower System, operated by our Ombudsman, is generally available to anyone who can provide information about unlawful conduct. This includes employees, customers, or other third parties. We accept all reports where you suspect a violation and which fall within the specified subject area.

What topics can be reported?

The whistleblower system is available for reporting violations of laws and regulations, as well as human rights and environmental risks and breaches of due diligence, provided these affect our company, our business unit, or our suppliers along the entire supply chain.

The topics covered by the whistleblower system include, in particular, the following:

Corruption, money laundering, bribery, terrorist financing, export control violations
Anticompetitive behavior
Violations of the Code of Conduct and other internal TQGG guidelines (e.g., purchasing guidelines)
Product safety
Discrimination, bullying, fundamental rights
Health, operational safety, occupational health and safety
Personnel issues, including disregard for work instructions
Data protection and information security violations
Antitrust violations
EU matters as defined by the EU Whistleblower Directive 2019/1937
Violations of human rights and environmental due diligence obligations.

The whistleblower system is not intended for complaints related to day-to-day operations. Reports submitted through the whistleblower system that concern matters outside the defined scope will be forwarded to the appropriate contact persons, subject to the whistleblower's consent, or the appropriate contact persons will be designated.

How can reports be submitted?

TQGG:

Our employees can report any issues to their supervisors, the HR department, the General Counsel, or other relevant departments within the company at any time.

Whistleblower System / Ombudsman:

Our whistleblower system is also available to our employees, business partners, and other third parties, allowing them to submit reports to our Ombudsman. You can submit your reports by phone, mail, email, or in person.

Attorney Dr. Kathrin J. Niewiarra, Ombudsman

Philippistrasse 11

D-14059 Berlin

Tel.: +49 (0) 30 / 4036750-17

TQGG@compliance-aid.com

Reports can be submitted in German and English.

Furthermore, reports can be submitted to the Ombudsperson via our electronic whistleblower system in over 26 languages:

How is anonymity ensured and the whistleblower protected?

The protection and confidentiality of the whistleblower are essential components of our complaints procedure and are taken very seriously. Throughout the entire process, individual measures are developed and implemented on a case-by-case basis to guarantee the whistleblower's protection from discrimination or punishment as a result of submitted reports. Intimidation, threats, or discrimination against whistleblowers in the workplace will not be tolerated. If you experience intimidation, threats, or reprisals as a result of a report, please contact our Ombudsperson or the relevant departments at TQGG.

As a lawyer, the Ombudsperson is also bound by attorney-client privilege. All contact, information, and reports will be treated with absolute confidentiality. This is secured by a separate data protection agreement with TQGG as the client.

Your identity will only be disclosed to TQGG with the explicit consent of the whistleblower. Should your information lead to investigations by law enforcement agencies, your anonymity is guaranteed by attorney-client privilege, even with respect to these institutions.

What happens to a submitted tip?

Summary:

The ombudsperson reviews the incoming tips and takes legal action.