Privacy Notice/ Rules of Procedure for the "Let us know" Compliance Whistleblower System – Phone

The key points at a glance:

Anonymous reporting

• You can send us information without disclosing your identity.
• Communication will then take place using an automatically generated case number and password, which you can use to stay in contact with us via this whistleblower system.
• There is no way that your identity can be traced by any other means, such as via your IP address.
   

If you do not wish to remain anonymous:

• By voluntarily choosing not to submit your information anonymously, you expressly consent to the processing of your identification data (Article 6(1)(a) of the General Data Protection Regulation (GDPR)).
• The information provided and your identity will be treated as strictly confidential. This can only be viewed by employees of the National and/or Corporate Compliance Office and, to the extent necessary, by system administrators.
• Your identity is revealed only if Klöckner is legally obliged to do so or this is essential for investigation purposes and/or for enforceability of claims. Therefore, it cannot be completely ruled out that your identity will have to be revealed to investigating authorities or in court proceedings at a later date.
• In order to protect their rights, people whose identity you disclose via the Compliance Whistleblower System will be informed of the reported incident received and the accusations made as soon as this no longer compromises investigations.
• Klöckner guarantees that whistleblowers are in no way placed at a disadvantage as a result of their reporting an incident, unless they have knowingly distributed false information, misused the whistleblower system in any other way or incriminated themselves.
• We ensure that, if you break off entering data, no data on the matter will be stored or submitted.

Finally, please note that you can report matters to the competent external public reporting bodies. In Germany, for example, the competent body is the Federal Government’s reporting body at the Federal Office of Justice (Bundesamt für Justiz/BfJ): https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html

In the European Union, for example, the EU Commission: https://ec.europa.eu/assets/sg/report-a-breach/complaints_en/

In the United Kingdom: Welcome to the Parliamentary and Health Service Ombudsman | Parliamentary and Health Service Ombudsman (PHSO)

In the United States of America: ReportFraud.ftc.gov

Special notice on revocation of consent

As a rule, it is possible to revoke consent only within one month of submitting the information, as we are required to follow up on the matter and also to notify the accused individual about the allegations made against them as well as about the investigations that have been taken up or completed. In individual cases, the revocation period may be shorter, such as when the nature of the information provided requires the immediate involvement of a public authority or a court.

Send your revocation to dataprivacy@kloeckner.com.