Compliance

Our corporate culture is characterised by clear responsibility, mutual respect and trust in our business partners and employees. However, this does not rule out the risk of infringement of the law and/or individual misconduct with absolute certainty.

Groupe SEB’s subsidiaries in Germany and its affiliated companies strive to minimise these risks. A compliance organisation and a global ombudsman system has been set up for this purpose. Both employees and third parties (customers, suppliers, etc.) can confidentially and – upon request – anonymously contact an external, independent lawyer should they have any information about economic offences, infringements of anti-trust law or breaches of internal guidelines, for example. His contact details are as follows:

Dr Carsten Thiel von Herff, LL.M. (lawyer)
Loebellstraße 4
33604 BIELEFELD
GERMANY

Freephone*: 00800 “OMBUDSMANN” = 00800 6628376266

*Calls made to the 00800 number are free for callers based in the following countries: Austria, Belgium, China, the Czech Republic, France, Germany, Italy, Japan, the Netherlands, Singapore, Spain, Switzerland, the UK and the USA.

The designated lawyer can also be anonymously contacted through „commUNITYcate“, the  certified compliance whistleblower system. In offering this system, we are providing all of the employees and business partners with a protected and confidential channel for reporting compliance breaches:

commUNITYcate

External reporting channels

In addition to reporting grievances to the internal reporting office, you can also report them to an external reporting office. Section 7 para. 1 sentence 1 of the Whistleblower Protection Act (HinSchG) provides for a right to choose. According to Section 7 (1) sentence 2 HinSchG, whistleblowers should prefer to report to an internal reporting office in cases where effective internal action can be taken against the violation and they do not fear reprisals.

External reporting office of the federal government

In addition to internal reporting, the law provides for the possibility of external reporting. To this end, the federal government is setting up the external federal reporting office at the Federal Office of Justice (FOCJ). From July 2, 2023, the reporting channels through which whistleblowers can contact the external federal reporting office will be published on the BfJ website. Further information on the BfJ’s external reporting office can be found here:

https://www.bundesjustizamt.de/hinweisgeberstelle.html?nn=13736

In addition to the Federal Government’s external reporting office at the BfJ, the existing reporting systems at the Federal Financial Supervisory Authority (BaFin) and the Federal Cartel Office will continue to be maintained for their specific areas of responsibility. Please also read the information on the websites of these reporting offices/whistleblowers:

www.bafin.de
www.bundeskartellamt.de

Information on procedures for notifications to bodies of the European Union (EU)

In addition to information on external reporting procedures under the HinSchG, you can access information on procedures for reporting to EU institutions, bodies, offices and agencies via the following links. These include external reporting channels of the Commission, the European Anti-Fraud Office (OLAF), the European Maritime Safety Agency (EMSA), the European Aviation Safety Agency (EASA), the European Securities and Markets Authority (ESMA) and the European Medicines Agency (EMA).

OLAF: https://anti-fraud.ec.europa.eu/index_de
EMSA: https://www.emsa.europa.eu/de
EASA: https://www.easa.europa.eu/en
ESMA: https://www.esma.europa.eu/
EMA: https://www.ema.europa.eu/en

The reporting procedures there remain unaffected by the HinSchG, i.e. they continue to exist unchanged alongside the internal and external reporting procedures under the HinSchG.

Further information on external reporting bodies and EU procedures

Further information on external reporting procedures and relevant reporting procedures of institutions, bodies, offices and agencies of the European Union can be found on the BfJ website and can be accessed here:

https://www.bundesjustizamt.de/DE/MeldestelledesBundes/Fragen/Fragen_node.html#AnkerDokument96692