Whistleblower Hotline
4C has established an anonymous reporting channel, the Whistleblower Hotline. Employees, clients and contractual partners can use it to report potential compliance violations anonymously. Under the German Whistleblower Protection Act (Hinweisgeberschutzgesetz), employers with generally at least 50 employees must establish an internal reporting office. The law does not require reporting channels to be technically designed to allow anonymous reports; however, anonymously submitted reports should be processed. 4C takes this responsibility seriously because both the wellbeing of our employees and professional collaboration with external partners are among our highest priorities.
Attorney Dr Anna Lena Glander and attorney Dr André-M. Szesny, LL.M., serve as external compliance counsel for 4C GROUP AG.
They are available to employees, clients and contractual partners wishing to report potential compliance violations to 4C GROUP. They serve as additional contacts alongside the internal Compliance Officer, Stephan Grunwald (Executive Board Member for Human Resources). Individuals submitting reports incur no costs by consulting the external compliance counsel.
Contact details for our external compliance counselReports may be submitted to our outsourced reporting office by email, in person or by telephone using the following contact details:
Attorney
Dr Anna Lena Glander
HEUKING
- a.glander@heuking.de
- Telephone
- +49 211 600 55-336
- Fax
- +49 211 600 55-210
- Website
- Profile on heuking.de
Attorney
Dr André-M. Szesny, LL.M.
HEUKING
- a.szesny@heuking.de
- Telephone
- +49 211 600 55-217
- Fax
- +49 211 600 55-210
- Mobile
- +49 179 475 60 74
- Website
- Profile on heuking.de
When should I contact the external compliance counsel?For individuals inside and outside the company
Individuals inside and outside the company may request a personal and confidential conversation and may remain anonymous. Dr Anna Lena Glander and Dr André-M. Szesny, LL.M., are available as 4C’s external compliance counsel.
Reports may concern:
- Corruption offences and cases of fraud, including fraud, breach of trust and misappropriation;
- Antitrust violations;
- Violations of equality and diversity policies, bullying, stalking or sexual harassment where substantiated conduct could result in the dismissal of employees or managers;
- Conduct that damages the company’s reputation and violates the Code of Conduct;
- Intentional data protection violations;
- Serious breaches of internal policies or work instructions;
- Violations of statutory rules concerning the prevention of money laundering and terrorist financing.
When should I not contact the external compliance counsel?Not responsible for
- Client complaints concerning a contractual relationship or the performance of services, unless they relate to one of the matters listed above;
- Reports concerning minor breaches of internal or external rules;
- Reports concerning only the performance of 4C GROUP AG employees and not any of the types of violation listed above.
Confidentiality and data protectionWhistleblower Policy
We generally assure you of confidentiality regarding the information and personal data you submit.
Before your report is forwarded to 4C GROUP, you may ask the reporting office to anonymise it or submit it anonymously from the outset.
Protection from reprisals
Under the German Whistleblower Protection Act, reporting persons are protected from reprisals if, at the time of reporting, they had reasonable grounds to believe that the information reported was true and concerned a violation within the scope of the Act. If a report submitted under these conditions later proves to be incorrect, this does not remove that protection. Reprisals against reporting persons, including threats and attempted reprisals, are prohibited. Knowingly false statements are not covered by this protection.
4C GROUP AG carefully follows up on all reports. We provide reporting persons with the greatest possible confidentiality and ensure a fair investigation. The same fairness applies to all employees accused of a violation. Reports may also be submitted anonymously. Please provide as much detail as possible and include any attachments or documents that support your concerns. An allegation can be investigated and lead to appropriate action only if sufficiently specific indications are available.
Read further data protection information.