Let us know

LET US KNOW

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 please click here.

To leave a report by phone, please click here.

Data Protection Notice/Information about the "Let us know" Compliance Whistleblower-System

Please read this Data Protection Notice through carefully before you provide a tip-off, and agree to the content of the following information:

The most important in a nutshell:

Anonymous reporting

You have the option to provide us with information without revealing your identity.

Communication will then take place via an automatically generated case ID and password, which you can use to stay in contact with us via our whistleblower system.

A tracing of your identity via other means, e.g. your IP address, is precluded.

If you don't want to remain anonymous

Information provided by a whistleblower and his/her identity will be treated as strictly confidential. This can only be viewed by employees of the Corporate Compliance Office and, to the extent necessary, by system administrators.

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.

Detailed Version

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:

General Data Protection Regulation: The General Data Protection Regulation (GDPR) is a European Union (EU) law governing the protection of personal data. The information provided here serves to fulfill a legal requirement under the GDPR.
Personal data: Personal data is all information relating to a data subject. A data subject is an identified or identifiable natural person. An identifiable natural person is a person who can be identified by name or other data. Personal data includes contact details, IP address, age and many other items of information.
Processing: Under Article 4(2) of the GDPR, processing is any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Controller: Under Article 4(7) of the GDPR, a controller is a natural or legal person which determines the purposes and means of, and thus controls, the processing of personal data.

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: dataprivacy@kloeckner.com.

2. Information on processing
The "Let us know" Compliance Whistleblower-System (“Compliance Whistleblower-System”) 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);
Serious data protection breaches;
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.

Use of the Klöckner Compliance Whistleblower-System 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. 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 close/exit this homepage. In this case, you may not report a tip-off via the Compliance Whistleblower-System. You may then approach your designated Compliance Officer.

We ensure that if data entry is cancelled, 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 Whistleblower-System, 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;
Name(s) and personal data of person(s) you have specified in your tip-off (such as job title(s) and 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.

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.
As long as the possibility of reporting anonymously has not been used, the 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 Whistleblower-System 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 Whistleblower-System 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 Whistleblower-System 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 Whistleblower-System 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:

GAN Integrity
345 7th Avenue
New York, NY 10001
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 Whistleblower-System, 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, to have it corrected, erased 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.

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:

The right to be provided information about the data processing and a copy of the processed data (right of access, Article 15 of the GDPR);
The right to obtain rectification of incorrect data or to have incomplete data completed (right to rectification, Article 16 of the GDPR);
The right to obtain erasure of personal data and, where personal data has been made public, to have other controllers informed about the request for erasure (right to erasure, Article 17 of the GDPR);
The right to obtain restriction of processing (right to restriction of processing, Article 18 of the GDPR);
The right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to transmit that data to another controller (right to data portability, Article 20 of the GDPR);
The right to object to data processing in order to prevent it (right to object, Article 21 of the GDPR);
The right to withdraw consent that you have given in order to prevent data processing on the basis of your consent. Revoking consent has no bearing on the lawfulness of processing on the basis of the consent before the revocation (right of withdrawal, Article 7 of the GDPR);
The right to lodge a complaint with a supervisory authority if you consider that the processing of personal data infringes the GDPR (right to lodge a complaint with a supervisory authority, Article 77 of the GDPR)

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