Report Compliance incidents

ANONYMOUS

We always strive to meet our own requirements and those of our business partners. Therefore, we always adapt our processes and conduct to laws and internal guidelines.

We would like to encourage all employees, business partners and other third parties to report to us any violations of legal or internal requirements that have been identified or even suspected in good faith – either by stating their own name or anonymously. This is the only way we can improve.

Our Compliance contact person, Ms. Alina Gläßer, can be reached via the following reporting channels:

Reports can be sent in German, English, French or Slovak.

The receipt of reports received by e-mail, post or via the reporting tool will be confirmed within 7 days. The whistleblower will be informed about follow-up measures within 3 months at the latest. At the request of the whistleblower, a personal meeting is also possible.

In the case of an anonymous report, we will not take any steps that would lead to the anonymity of the reporter being revealed. The reporting tool is technically set up in such a way that it is not possible to trace the sender of an anonymous report (including IP address).

All reports are received and processed throughout the CANCOM Group by the central compliance department of CANCOM SE. The original responsibility for the reaction to the reported violation (e.g. follow-up measures) remains with the respective company. In the course of the necessary coordination between CANCOM SE and the
company concerned, it may be necessary to pass on information to the responsible persons in these companies.

Incoming reports and the resulting internal investigations, the involvement of authorities if necessary, and the resulting measures are documented comprehensively but confidentially by the Compliance Officer. Authorities such as the police, the public prosecutor’s office, and/or supervisory authorities are called in after the facts of the
case have been determined and if necessary.

CANCOM ensures that no person is terminated, transferred to a low-grade position, suspended, threatened, harassed, or discriminated against in any way as a result of a bona fide report.

There will be no sanctions of any kind against the bona fide reporter under any circumstances. This applies subject to conflicting legal requirements (e.g. Section 125 (1) Sentence 1 No. 3 GWB, self-cleaning under antitrust law).

In addition to the internal offices, external offices are also available to whistleblowers for reports. For example, reports can be made to the central external reporting office at the Federal Office of Justice (BfJ), to the Federal Financial Supervisory Authority (BaFin) and to the Federal Cartel Office (Bundeskartellamt) as well as to reporting offices at European institutions (e.g. OLAF, ESMA).