Privacy

 

 

 
Whistleblower Protection Act
 

Whistleblowing System

of the Schmidt + Clemens Group

Do you have knowledge or even just a suspicion of misconduct or legal violations within the Schmidt + Clemens Group? Then please inform our internal Reporting Offices. By doing so, you are protecting and supporting us all. We will treat your data confidentially, and you can choose to remain anonymous. We follow up on all reports carefully and responsibly.

If you make a report, please describe the facts of the case as precisely as possible, name the company concerned, the persons involved, the time and place of the incident and provide the names of any witnesses. If possible, also submit documents such as pictures, emails, etc. that support your suspicions.

The following Reporting Offices can receive reports:

Internal Reporting Office of Schmidt + Clemens GmbH + Co KG

  • Internal Reporting Office within the meaning of the German Whistleblower Protection Act
  • Also functions as the global Reporting Office of the Schmidt + Clemens Group

Internal Reporting Office of Schmidt-Clemens Spain, S.A.U. (Spain)

  • Internal Reporting Office within the meaning of the Spanish Whistleblower Protection Act

Internal Reporting Office of S+C Alfanametal s.r.o., concern (Czech Republic)

  • Internal Reporting Office within the meaning of the Czech Whistleblower Protection Act
 
The internal reporting office
 

The Internal Reporting Office of Schmidt + Clemens Group

Schmidt + Clemens GmbH + Co. KG has set up an internal Reporting Office for itself and for all companies affiliated with Schmidt + Clemens GmbH + Co. KG (jointly “Schmidt + Clemens Group” or “Schmidt + Clemens”) to receive reports of grievances and misconduct. This Reporting Office is also open to employees of other companies in the Schmidt + Clemens Group.

Schmidt + Clemens GmbH + Co. KG has commissioned the law firm Heuking (“outsourced internal reporting office”) to receive reports, liaise with whistleblowers and conduct the initial legal review.

Whistleblowers can submit their report in German or English in person, by telephone, by letter or by email to

Lawyer Dr. André-M. Szesny, LL.M.

Heuking Kühn Lüer Wojtek Partnerschaftsgesellschaft von Rechtsanwälten mbB

Georg-Glock-Straße 4
40474 Düsseldorf, Germany

E-Mail: a.szesny(at)heuking.de
Tel: +49 211 60055-217

Whistleblowers can also submit their reports via the WhistleFox web form:

Web form (German)
Web form (English)
Web form (Spanish)
Web form (Czech)

 
The Local Reporting Offices
 

The Local Reporting Offices of the Schmidt + Clemens Group

Schmidt-Clemens Spain, S.A.U. (Spain) and S+C Alfanametal s.r.o., concern (Czech Republic) have also set up their own local Reporting Offices pursuant to national legislation. These are available to employees in addition to the Schmidt + Clemens Group central Reporting Offices.


The local Reporting Offices can be contacted as follows:

Internal Reporting Office of Schmidt-Clemens Spain, S.A.U. (Spain)

José Ramón Echeverría
               
Schmidt-Clemens Spain, S.A.U.
Canal Denuncias (Att. J. Ramón Echeverría)
Polígono Industrial no2
31280 Murieta (Navarra-Spain.)

E-Mail: canaldenuncias(at)schmidt-clemens.com
Tel: +34 948 53 46 61

Internal Reporting Office of S+C Alfanametal s.r.o., concern (Czech Republic)

JUDr. Miroslav Pokorný / JUDr. Petr Matèjka

AK Pokorný & Matèjka
Lidická 23b
602 00 Brno (Czech Republic)

E-Mail: whistleblowing(at)pokorny-matejka.cz
Tel: +42 0 541247872

Please note that only the local Reporting Offices are “internal Reporting Offices” within the meaning of the applicable local law.

 
FAQs
 

Frequently Asked Questions

The following statements apply to the internal Reporting Office of Schmidt + Clemens GmbH + Co KG (Germany). There may be deviations depending on the applicable local law.

What can I report?

You can help us by making a report if you have indications that employees of the Schmidt + Clemens Group or other individuals are acting against our interests or otherwise acting improperly. This includes serious compliance violations and criminal offences such as corruption and fraud, theft and embezzlement, coercion and mobbing, but also other rule violations, such as discrimination, abuse of power or environmental or human rights-related risks and other violations of obligations. Violations that have not yet occurred but appear imminent or planned may and should be reported. Mere suspicions can also be reported. Even if these subsequently turn out to be unfounded, there is no threat of any disadvantages for the whistleblower.

However, the whistleblowing system is not suitable for general complaints and reporting emergencies!

How are reports made?

Please describe the facts of the case as precisely as possible. Name the organisation or organisation unit and people involved, along with the time and place of the incident. Also provide the names of possible witnesses.

If possible, also submit documents such as pictures, emails, etc. that support your suspicions.

You decide which data you will provide, whether you want to remain anonymous or whether you want to make yourself available to the persons of trust whom we have appointed for follow-up questions. Please follow the instructions of the local Reporting Offices.

The internal Reporting Office will provide confirmation of the receipt of your report within seven days, provided that you have given your contact details. Within a further three months, you will receive feedback on the further handling of your report and the measures taken, insofar as this does not jeopardise ongoing internal investigations and does not affect the rights of third parties.

Our lawyers of trust will review your report and inform the appropriate office at Schmidt + Clemens GmbH + Co KG in accordance with the law and data protection regulations. If necessary, the latter will forward the report to the relevant competent Reporting Office or the relevant competent company (e.g. the internal Reporting Offices of Schmidt-Clemens Spain, S.A.U. (Spain) or of S+C Alfanametal s.r.o., concern (Czech Republic). They then take the necessary follow-up measures, as required.

How is my data protected?

All personal details will be treated confidentially. If you wish, you may submit your report anonymously.

The whistleblowing system complies with applicable legal requirements. All reports are received by lawyers of trust and responsibly processed before they are forwarded to the Schmidt + Clemens GmbH + Co. KG office in charge of handling whistleblower reports.

The documentation of your report at Schmidt + Clemens GmbH + Co. KG will be deleted no later than three years after the conclusion of the procedure, insofar as legal regulations do not prevent this.

Will I be at a disadvantage if I make a report?

Whistleblowers are subject to legal protection if they have reasonable grounds to believe that the reported information is true at the time they share it with the internal Reporting Office.

For this scope of protection to apply, the report must concern a matter that falls under the German Whistleblower Protection Act or other relevant laws, i.e. in particular criminal offences and serious administrative offences. The report must also refer to the Schmidt + Clemens Group or another organisation with which you as the whistleblower are or were in professional contact.

Whistleblowers may not suffer disadvantages under labour law in these cases, even if a reported suspicion subsequently turns out to be unfounded.

How can I submit a report?

There are various reporting channels available to you: You can submit your report to the Reporting Offices using the above-mentioned web forms or in person, by telephone, by email or by letter using the contact details given above.

you also have the option of submitting your report to a governmental reporting office. The Compliance Department and the outsourced internal Reporting Office provide information about these external federal and state Reporting Offices.

However, the law stipulates that you, as the whistleblower, should choose to report to the internal Reporting Office mentioned rather than to the external official Reporting Office, if effective action can be taken internally against violations.

Whom can I contact if I am unsure of whether I should use the whistleblowing system?

If you have any queries, you can contact the Reporting Office by telephone or email using the contact details given above. If in doubt, however, it does make sense to use the whistleblowing system. Our lawyers of trust handle incoming reports carefully and conscientiously, and process them based on a wealth of experience.

 

 
Data Protection
 

Data Protection

The Data Protection Notice of Schmidt + Clemens GmbH + Co KG applies to data processing of whistleblower reports within Schmidt + Clemens.

The Data Protection Notice provided here applies to data processing carried out by Heuking Kühn Lüer Wojtek.

 
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