You may print the content of this data protection information and Declaration of Consent here:
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.
To leave a report by phone, please click here.
1. General information
a) Introduction
In this Data Protection Notice, we would like to inform you about the processing of your personal data and your rights regarding this processing.
b) Definitions
Definitions of terms used in this Data Protection Notice:
c) Controller
We, Klöckner & Co SE, Am Silberpalais 1, 47057 Duisburg, are the controller within the meaning of the GDPR and therefore control the data processing covered in the following. If you have any questions or requests regarding data processing, please contact our Data Protection Officer using the contact details in the next paragraph.
d) Data Protection Officer
You can contact our Data Protection Officer using the following contact details at any time:
E-mail: datenschutzbeauftragter@kloeckner.com.
2. Information on processing
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:
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 Notice and have given your express consent for the information provided by you 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 Notice. Only then will you be able to access the report form. If you do not wish to give your consent for the disclosures you make 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.
3. Information on processing
a) Data categories
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:
b) Purposes of processing
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 ruled out that his/her identity will have to be revealed at a later date to investigating 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 GDPR as well as all other applicable data protection regulations 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.
c) Legal basis of processing
Processing is performed as a rule on the basis of Article 6(1)(a) (consent), in some cases on the basis of Article 6(1)(c) for compliance with a legal obligation to which we are party (compliance with a legal obligation) and occasionally on the basis of Article 6(1)(f) of the GDPR for the purposes of our legitimate interests, except where such interests are overridden by the legitimate interests or fundamental rights of the data subject (for the purposes of legitimate interests).
d) Voluntary provision of data
Use of the Klöckner “Let us know” 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 Notice and have given your express consent for the information provided by you to be processed.
e) Storage period
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 or enforce claims; for as long as it is required 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 erased no later than two months after investigations have been completed.
f) Recipients of personal data
Personal data provided to us via the Klöckner “Let us know” Compliance Helpdesk can normally only be viewed by Compliance Organization employees.
In exceptional instances, it may be necessary to involve other trusted parties such as the Data Protection Officer or the Works Council.
g) Transfer to third countries
The website you are forwarded to after submitting your consent is operated by our service provider:
NAVEX Global, Inc.
6000 Meadows Road
Suite 200
Lake Oswego, OR 97035
USA
This company is headquartered in the USA, 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 ruled out that government authorities, especially US authorities, may access your data in a way that would be excessive by a German or European understanding of the law. Furthermore, it cannot be ruled out 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.
4. 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:
5. Your rights
As a data subject, you can exercise your rights under the GDPR at any time by sending an informal message to our Data Protection Officer (see under heading 1. d) above for contact details). Your rights are as follows:
I have read the above Data Protection 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:
1. General information
a) Introduction
In this Data Protection Notice, we would like to inform you about the processing of your personal data and your rights regarding this processing.
b) Definitions
Definitions of terms used in this Data Protection Notice:
c) Controller
We, Klöckner & Co SE, Am Silberpalais 1, 47057 Duisburg, are the controller within the meaning of the GDPR and therefore control the data processing covered in the following. If you have any questions or requests regarding data processing, please contact our Data Protection Officer using the contact details in the next paragraph.
d) Data Protection Officer
You can contact our Data Protection Officer using the following contact details at any time:
E-mail: datenschutzbeauftragter@kloeckner.com.
2. Information on processing
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:
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 Notice and have given your express consent for the information provided by you 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 Notice. Only then will you be able to access the report form. If you do not wish to give your consent for the disclosures you make 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.
3. Information on processing
a) Data categories
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:
b) Purposes of processing
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 ruled out that his/her identity will have to be revealed at a later date to investigating 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 GDPR as well as all other applicable data protection regulations 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.
c) Legal basis of processing
Processing is performed as a rule on the basis of Article 6(1)(a) (consent), in some cases on the basis of Article 6(1)(c) for compliance with a legal obligation to which we are party (compliance with a legal obligation) and occasionally on the basis of Article 6(1)(f) of the GDPR for the purposes of our legitimate interests, except where such interests are overridden by the legitimate interests or fundamental rights of the data subject (for the purposes of legitimate interests).
d) Voluntary provision of data
Use of the Klöckner “Let us know” 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 Notice and have given your express consent for the information provided by you to be processed.
e) Storage period
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 or enforce claims; for as long as it is required 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 erased no later than two months after investigations have been completed.
f) Recipients of personal data
Personal data provided to us via the Klöckner “Let us know” Compliance Helpdesk can normally only be viewed by Compliance Organization employees.
In exceptional instances, it may be necessary to involve other trusted parties such as the Data Protection Officer or the Works Council.
g) Transfer to third countries
The website you are forwarded to after submitting your consent is operated by our service provider:
NAVEX Global, Inc.
6000 Meadows Road
Suite 200
Lake Oswego, OR 97035
USA
This company is headquartered in the USA, 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 ruled out that government authorities, especially US authorities, may access your data in a way that would be excessive by a German or European understanding of the law. Furthermore, it cannot be ruled out 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.
4. 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:
5. Your rights
As a data subject, you can exercise your rights under the GDPR at any time by sending an informal message to our Data Protection Officer (see under heading 1. d) above for contact details). Your rights are as follows:
I have read the above Data Protection 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:
1. General information
a) Introduction
In this Data Protection Notice, we would like to inform you about the processing of your personal data and your rights regarding this processing.
b) Definitions
Definitions of terms used in this Data Protection Notice:
c) Controller
We, Klöckner & Co SE, Am Silberpalais 1, 47057 Duisburg, are the controller within the meaning of the GDPR and therefore control the data processing covered in the following. If you have any questions or requests regarding data processing, please contact our Data Protection Officer using the contact details in the next paragraph.
d) Data Protection Officer
You can contact our Data Protection Officer using the following contact details at any time:
E-mail: datenschutzbeauftragter@kloeckner.com.
2. Information on processing
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:
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 Notice and have given your express consent for the information provided by you 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 Notice. Only then will you be able to access the report form. If you do not wish to give your consent for the disclosures you make 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.
3. Information on processing
a) Data categories
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:
b) Purposes of processing
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 ruled out that his/her identity will have to be revealed at a later date to investigating 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 GDPR as well as all other applicable data protection regulations 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.
c) Legal basis of processing
Processing is performed as a rule on the basis of Article 6(1)(a) (consent), in some cases on the basis of Article 6(1)(c) for compliance with a legal obligation to which we are party (compliance with a legal obligation) and occasionally on the basis of Article 6(1)(f) of the GDPR for the purposes of our legitimate interests, except where such interests are overridden by the legitimate interests or fundamental rights of the data subject (for the purposes of legitimate interests).
d) Voluntary provision of data
Use of the Klöckner “Let us know” 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 Notice and have given your express consent for the information provided by you to be processed.
e) Storage period
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 or enforce claims; for as long as it is required 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 erased no later than two months after investigations have been completed.
f) Recipients of personal data
Personal data provided to us via the Klöckner “Let us know” Compliance Helpdesk can normally only be viewed by Compliance Organization employees.
In exceptional instances, it may be necessary to involve other trusted parties such as the Data Protection Officer or the Works Council.
g) Transfer to third countries
The website you are forwarded to after submitting your consent is operated by our service provider:
NAVEX Global, Inc.
6000 Meadows Road
Suite 200
Lake Oswego, OR 97035
USA
This company is headquartered in the USA, 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 ruled out that government authorities, especially US authorities, may access your data in a way that would be excessive by a German or European understanding of the law. Furthermore, it cannot be ruled out 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.
4. 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:
5. Your rights
As a data subject, you can exercise your rights under the GDPR at any time by sending an informal message to our Data Protection Officer (see under heading 1. d) above for contact details). Your rights are as follows:
I have read the above Data Protection 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:
