Whistleblower report

This reporting office is responsible for any violation under § 2 HinSchG. This means all violations that are punishable or subject to a fine.

In addition, certain violations of federal or state laws and directly applicable legal acts of the EU and the European Atomic Energy Community can be reported. The reported violations must be related to professional activity, as the internal reporting office is not responsible for information about private misconduct. The connection to professional activity is interpreted broadly.

For example, if you suspect that someone has stolen property from NOW or that there has been a violation of the General Data Protection Regulation when processing personal data, please contact this reporting office.

In addition, the scope of this reporting office for employees has been expanded to include the Compliance Management System (CMS). In addition to violations under § 2 HinSchG, reports on the CMS can now also be submitted. This includes, for example, suggestions for improvement or information on risks. Reports on the CMS are also anonymous.

Your report of violations should contain the following information:

• Information about the type of misconduct you want to report.

• Information about where and when this misconduct took place.

• All documents available to you (redacted if necessary to protect anonymity). If you do not have access to the relevant documents, but know that they exist, please indicate which documents they are and where they can be found.

• Information on measures you have taken in connection with the misconduct.

Before submitting your report, please read the section on “Data Protection” (see below). Personal data that does not play a role in your report should not be submitted. If you submit such information, we may delete it without informing you.

First, a colleague from the NOW GmbH whistleblower team will make an initial assessment of your report.

Each report is assigned a unique case number and you will receive an email within seven days confirming receipt of your report. If you would like to submit additional information, simply reply to this email.

The responsible colleagues will then take appropriate follow-up measures, such as conducting independent investigations, rectifying existing grievances, or handing the proceedings over to the investigating authorities (all possible measures can be found in § 18 HinSchG).

Finally, you will receive feedback within 90 days on how the case was handled.

Misconduct can also be reported externally to a competent authority that can follow up on whistleblower cases. There is the Federal Office of Justice, Federal Financial Supervisory Authority and the Federal Cartel Office a total of three external reporting offices, on whose homepage you can find further information.

When you submit a report, you remain completely anonymous unless you voluntarily provide personal data. However, there is no obligation to provide personal data. If you still decide to provide your NOW email address with your name, we guarantee discretion throughout the entire case processing process.

If you would like to submit a completely anonymous report, set up an anonymized email address, provide a pseudonym or a false name when submitting the report, and use the email mailbox for further communication. We recommend a completely anonymous report.