Information about cookies

We use cookies so that we can provide you with a better online experience. By clicking "accept" without changing the settings for the cookies you are agreeing to our use of cookies. For further information please refer to our cookie policy.

Header Image

Let us know

Deutsch | Español | Français

Klöckner & Co is committed to free competition and speaks out resolutely against corruption at all levels of business and social life. For this reason, ensuring maximum integrity in business is particularly important to us. Transparency in our business processes is one of our key cornerstones of success. We therefore wish to be informed of any breach of compliance regulations.

 

You can reach us on this site and inform us of breaches of compliance regulations around the clock. This service is directed at all employees of the Klöckner & Co Group, as well as customers, suppliers and other business partners. Tip-offs that you provide us with on this site will be encrypted and treated as strictly confidential. Reports received are not traced back and sender details are not recorded automatically.

We will handle your tip-off with all the necessary sensitivity and sincerity. The content of the report will be forwarded to our Corporate Compliance Office Germany. Processing will take place here.

For a report via internet within Europe please click here, for all other countries please click here.

You can also call us:

Country Dialing Number
Austria 800-298-322
Belgium 0800-7-8636
France 0800-901-146
Germany 0800-183-0769
Netherlands 0800-022-6158
Spain 900-9-91001
Switzerland 0800-56-3831
UK & N Ireland 0808-234-0104
Brazil 0800-892-0648
Mexico +1 855-560-6163
US 855-229-9351

 

Data protection information on the “Let us know” Compliance Help Desk and the Declaration of Consent

Please read through these explanations on data protection carefully before you provide a tip-off, and agree to the content of the following information:

1. What is the Klöckner & Co SE “Let us know” Compliance Helpdesk?

The “Let us know” Compliance Helpdesk (“Compliance Helpdesk”) is a web-based automated process aimed at preventing business crime and similarly serious conduct or conflicts of interest that are damaging to the company. It is a key component of the Compliance Program of Klöckner & Co SE, Am Silberpalais 1, 47057 Duisburg, Germany (“Klöckner”). Klöckner urges employees, suppliers, customers and other business partners to report serious breaches of regulations or conflicts of interest on the part of employees, suppliers, customers or other business partners of Klöckner.

Serious misconduct and conduct that violates penal provisions or human rights, or conduct that is hugely out of line with the corporate interests of Klöckner constitute serious breaches of regulations and conflicts of interest. This includes, in particular:

  • Banking and financial crime;
  • Breaches of securities provisions including prohibited insider trading;
  • Breaches of fair competition and antitrust law;
  • Falsification and concealment of contracts, reports or records;
  • Corruption (bribery and granting advantages);
  • Other criminal offenses that affect company interests, in particular deception, embezzlement, theft and fraud;
  • Misconduct as regards accounting, internal accounting controls, auditing and drawing up the balance sheet;
  • Serious breaches of environmental regulations;
  • Conflicts of interest that are quite clearly an obstacle to carrying out duties for Klöckner while acting in the best interests of the company and which may lead to considerable damage to the assets or reputation of Klöckner.

Please bear in mind that all disclosures you provide about yourself, about reported employees, suppliers, customers or other business partners of the Klöckner & Co Group or about any other matters that are linked to Klöckner may lead to decisions that could have serious consequences for employees of Klöckner and any third parties that are implicated in the event which you have reported. For this reason, we ask that you only provide us with information that is correct to the best of your knowledge. The information that you provide will be treated as strictly confidential. We ask that you disclose your identity, as we will only follow up anonymous tip-offs in particularly serious cases.

Use of the Klöckner Compliance Helpdesk is voluntary. However, please be aware that we can only accept and process reports once you confirm that you have read and taken note of this data protection information and have given your express consent for the information you have provided to be processed. We therefore ask that you declare your consent first of all by marking a cross in the box “I give my consent” before you click on “Next” at the end of this data protection information. Only then will you be able to access the report form.

If you do not wish to give your consent for the disclosures you have made as regards personal data and information to be processed, please click on “Cancel” and you will be directed to the Klöckner & Co homepage. In this case, you may not report a tip-off via the Compliance Helpdesk. You may then approach your designated Compliance Officer.

We ensure that if data entry is cancelled by clicking on the Cancel button at the bottom of the data entry screen, no data whatsoever will be saved or transmitted regarding this event.

You may consult the content of your Declaration of Consent at any time. You may also revoke your consent at any time, to be effective in future, by contacting the following address:

Klöckner & Co SE
Corporate Compliance Office
Am Silberpalais 1
D-47057 Duisburg

or

compliance@kloeckner.com


2. Scope of personal data and information collected and processed

If you provide a tip-off via the Compliance Helpdesk, we will save the following personal data and other information, provided that this has been entered by you and that you have given your express consent for us to utilize this further:

  • Your name;
  • Your contact details and whether you are employed by Klöckner;
  • Names and personal details of persons you have specified in your tip-off, (e.g. descriptions of roles, contact details);
  • Any questions you may have;
  • Description of and details on the time and place the non-compliant conduct took place, and
  • Description of the situation upon which the tip-off is based;
  • Details on the Klöckner company affected;
  • Details on whether the management in question is aware of the non-compliant conduct.


3. Type of processing and scope of persons authorized to access personal data and other information regarding the tip-off

Klöckner will observe the data protection regulations in force, in particular the rights of the whistleblower and the accused. Information acquired by means of tip-offs will only be used for the purposes of investigating and taking action against serious breaches of regulations or conflicts of interest.

Information provided by a whistleblower and his/her identity will be treated as strictly confidential. The identity is only revealed if Klöckner is legally obliged to do so or this is necessary for investigation purposes and/or for enforceability of claims. Therefore, it cannot be completely excluded that your identity will have to be revealed at a later date to investigative authorities or a court. Klöckner ensures that a whistleblower is in no way placed at a disadvantage as a result of his/her tip-off, unless he/she has knowingly distributed false information, misused the whistleblower system in any other unauthorized way, or incriminated himself/herself.

In order to protect their rights, people whose identity you disclose via the Compliance Helpdesk will be informed of the tip-off received and the accusations made as soon as this no longer compromises investigations.

Aside from the tip-off itself, personal data and information will be saved in the Compliance Helpdesk database while the tip-off is processed further. This can only be viewed by employees of the Corporate Compliance Office and, to the extent necessary, by system administrators. These individuals are formally obliged to observe the requirements of the Federal Data Protection Act (BDSG) and to maintain confidentiality. This obligation also applies to employees of other internal or external bodies, insofar as their involvement is required for the purpose of clarification.

The personal data saved will only be stored for as long as it is required to process the tip-off and, if necessary, introduce sanctions, enforce claims, in connection with criminal prosecution measures or proceedings (e.g. joint plaintiff), or for as long as the data has to be stored by rights. Otherwise, the personal data will be deleted no later than two months after investigations have been completed.


4. Transmission to and data processing by service providers headquartered outside the European Economic Area

The website you are forwarded to after submitting your Declaration of Consent is operated by our service provider:

NAVEX Global, Inc.
6000 Meadows Road
Suite 200
Lake Oswego, OR 97035
USA


This company is headquartered outside the European Economic Area, meaning that it is not directly subject to European data protection law, but to US law. In this regard, US law is not equivalent to European law in every detail. Therefore, it cannot be completely excluded that government authorities, especially US authorities, may access your data in a way that would be excessive by German or European legal understanding. Furthermore, it cannot be excluded that legal redress against such access cannot be granted or cannot be granted to the same extent as it would be in Germany or to a US citizen.

Provided you agree to these data protection notifications below, you also agree to your data being forwarded to the service provider for the processing of your tip-off and to said service provider collecting, processing, and using it in the US.


5. What happens if I am affected by a tip-off myself, or if I am under suspicion?

If you yourself are affected by a tip-off issued to the Compliance Helpdesk, the appropriate office within the Klöckner & Co organization will contact you with regard to this as soon as this no longer compromises investigations.

We will inform you of the following:

  • The accusations that have been made against you;
  • The people or departments who are able to obtain information or reports on these accusations;
  • How you can exercise your right to obtain information on data saved about you personally and, if applicable, if this is amended, deleted or blocked.
  • If the transmission of any of this information impinges upon the rights of other parties, we will only transmit this information if we are legally obliged to do so.

I have read the above notice in full and agree to its content:

I give my consent and continue
Cancel

You may print the content of this data protection information and Declaration of Consent here:

Print

Data protection information on the “Let us know” Compliance Help Desk and the Declaration of Consent

Please read through these explanations on data protection carefully before you provide a tip-off, and agree to the content of the following information:

1. What is the Klöckner & Co SE “Let us know” Compliance Helpdesk?

The “Let us know” Compliance Helpdesk (“Compliance Helpdesk”) is a web-based automated process aimed at preventing business crime and similarly serious conduct or conflicts of interest that are damaging to the company. It is a key component of the Compliance Program of Klöckner & Co SE, Am Silberpalais 1, 47057 Duisburg, Germany (“Klöckner”). Klöckner urges employees, suppliers, customers and other business partners to report serious breaches of regulations or conflicts of interest on the part of employees, suppliers, customers or other business partners of Klöckner.

Serious misconduct and conduct that violates penal provisions or human rights, or conduct that is hugely out of line with the corporate interests of Klöckner constitute serious breaches of regulations and conflicts of interest. This includes, in particular:

  • Banking and financial crime;
  • Breaches of securities provisions including prohibited insider trading;
  • Breaches of fair competition and antitrust law;
  • Falsification and concealment of contracts, reports or records;
  • Corruption (bribery and granting advantages);
  • Other criminal offenses that affect company interests, in particular deception, embezzlement, theft and fraud;
  • Misconduct as regards accounting, internal accounting controls, auditing and drawing up the balance sheet;
  • Serious breaches of environmental regulations;
  • Conflicts of interest that are quite clearly an obstacle to carrying out duties for Klöckner while acting in the best interests of the company and which may lead to considerable damage to the assets or reputation of Klöckner.

Please bear in mind that all disclosures you provide about yourself, about reported employees, suppliers, customers or other business partners of the Klöckner & Co Group or about any other matters that are linked to Klöckner may lead to decisions that could have serious consequences for employees of Klöckner and any third parties that are implicated in the event which you have reported. For this reason, we ask that you only provide us with information that is correct to the best of your knowledge. The information that you provide will be treated as strictly confidential. We ask that you disclose your identity, as we will only follow up anonymous tip-offs in particularly serious cases.

Use of the Klöckner Compliance Helpdesk is voluntary. However, please be aware that we can only accept and process reports once you confirm that you have read and taken note of this data protection information and have given your express consent for the information you have provided to be processed. We therefore ask that you declare your consent first of all by marking a cross in the box “I give my consent” before you click on “Next” at the end of this data protection information. Only then will you be able to access the report form.

If you do not wish to give your consent for the disclosures you have made as regards personal data and information to be processed, please click on “Cancel” and you will be directed to the Klöckner & Co homepage. In this case, you may not report a tip-off via the Compliance Helpdesk. You may then approach your designated Compliance Officer.

We ensure that if data entry is cancelled by clicking on the Cancel button at the bottom of the data entry screen, no data whatsoever will be saved or transmitted regarding this event.

You may consult the content of your Declaration of Consent at any time. You may also revoke your consent at any time, to be effective in future, by contacting the following address:

Klöckner & Co SE
Corporate Compliance Office
Am Silberpalais 1
D-47057 Duisburg

or

compliance@kloeckner.com


2. Scope of personal data and information collected and processed

If you provide a tip-off via the Compliance Helpdesk, we will save the following personal data and other information, provided that this has been entered by you and that you have given your express consent for us to utilize this further:

  • Your name;
  • Your contact details and whether you are employed by Klöckner;
  • Names and personal details of persons you have specified in your tip-off, (e.g. descriptions of roles, contact details);
  • Any questions you may have;
  • Description of and details on the time and place the non-compliant conduct took place, and
  • Description of the situation upon which the tip-off is based;
  • Details on the Klöckner company affected;
  • Details on whether the management in question is aware of the non-compliant conduct.


3. Type of processing and scope of persons authorized to access personal data and other information regarding the tip-off

Klöckner will observe the data protection regulations in force, in particular the rights of the whistleblower and the accused. Information acquired by means of tip-offs will only be used for the purposes of investigating and taking action against serious breaches of regulations or conflicts of interest.

Information provided by a whistleblower and his/her identity will be treated as strictly confidential. The identity is only revealed if Klöckner is legally obliged to do so or this is necessary for investigation purposes and/or for enforceability of claims. Therefore, it cannot be completely excluded that your identity will have to be revealed at a later date to investigative authorities or a court. Klöckner ensures that a whistleblower is in no way placed at a disadvantage as a result of his/her tip-off, unless he/she has knowingly distributed false information, misused the whistleblower system in any other unauthorized way, or incriminated himself/herself.

In order to protect their rights, people whose identity you disclose via the Compliance Helpdesk will be informed of the tip-off received and the accusations made as soon as this no longer compromises investigations.

Aside from the tip-off itself, personal data and information will be saved in the Compliance Helpdesk database while the tip-off is processed further. This can only be viewed by employees of the Corporate Compliance Office and, to the extent necessary, by system administrators. These individuals are formally obliged to observe the requirements of the Federal Data Protection Act (BDSG) and to maintain confidentiality. This obligation also applies to employees of other internal or external bodies, insofar as their involvement is required for the purpose of clarification.

The personal data saved will only be stored for as long as it is required to process the tip-off and, if necessary, introduce sanctions, enforce claims, in connection with criminal prosecution measures or proceedings (e.g. joint plaintiff), or for as long as the data has to be stored by rights. Otherwise, the personal data will be deleted no later than two months after investigations have been completed.


4. Transmission to and data processing by service providers headquartered outside the European Economic Area

The website you are forwarded to after submitting your Declaration of Consent is operated by our service provider:

NAVEX Global, Inc.
6000 Meadows Road
Suite 200
Lake Oswego, OR 97035
USA


This company is headquartered outside the European Economic Area, meaning that it is not directly subject to European data protection law, but to US law. In this regard, US law is not equivalent to European law in every detail. Therefore, it cannot be completely excluded that government authorities, especially US authorities, may access your data in a way that would be excessive by German or European legal understanding. Furthermore, it cannot be excluded that legal redress against such access cannot be granted or cannot be granted to the same extent as it would be in Germany or to a US citizen.

Provided you agree to these data protection notifications below, you also agree to your data being forwarded to the service provider for the processing of your tip-off and to said service provider collecting, processing, and using it in the US.


5. What happens if I am affected by a tip-off myself, or if I am under suspicion?

If you yourself are affected by a tip-off issued to the Compliance Helpdesk, the appropriate office within the Klöckner & Co organization will contact you with regard to this as soon as this no longer compromises investigations.

We will inform you of the following:

  • The accusations that have been made against you;
  • The people or departments who are able to obtain information or reports on these accusations;
  • How you can exercise your right to obtain information on data saved about you personally and, if applicable, if this is amended, deleted or blocked.
  • If the transmission of any of this information impinges upon the rights of other parties, we will only transmit this information if we are legally obliged to do so.

I have read the above notice in full and agree to its content:

I give my consent and continue
Cancel

You may print the content of this data protection information and Declaration of Consent here:

Print

Ralf Oberhuber
Ralf Oberhuber

Head of Corporate Compliance Office

Contact info
Jeffrey Friedman
Jeffrey Friedman

Corporate Compliance Officer

Contact info

Code of conduct

Compliance Management System