Fritz Winter Eisengießerei GmbH & Co. KG aims to act ethically and in accordance with legal requirements in all its business activities; the integrity and transparency of our business processes have the highest priority. This applies worldwide and at all organizational levels.

Our compliance system is a comprehensive system of measures that we use to ensure that our business always fully complies with the law and our internal principles and rules. This includes, for example, violations of our Code of Conduct or antitrust law, corruption, violations of human rights, theft, discrimination or bullying. In addition to our employees, business partners, customers and/or other third parties can also report specific information on breaches of rules.

In order to give you the opportunity to report possible breaches of the law and rules, we have set up various reporting channels that can be used internationally. You have the option of submitting your report without stating your name. However, we recommend that you give our Compliance Office the opportunity to contact you, if necessary via a trusted person, as otherwise we will not have the opportunity to consult you if there is still a need for clarification and as the matter may not be able to be clarified further without your cooperation.

Who can report violations?

• Every employee, including trainees, interns or temporary workers
• External parties, e.g. employees of external service providers
• Every business partner, e.g. suppliers, customers or cooperation partners and their employees. Suppliers, customers or cooperation partners and their employees
• Any third party who has obtained information about the violations described below in connection with their professional activities or in advance of a professional activity.
   

Which violations should be reported?

Any specific events that indicate a criminal offense, e.g. fraud, bribery, theft, a violation of other legal regulations or a violation of our internal company regulations, e.g. the company code of conduct, can be reported. Human rights and environmental risks and violations can also be reported, including those identified in or along the supply chain.

What details should be reported?

• What type of misconduct is involved?
• When and where did it happen?
• How exactly did the suspected person or company proceed?
• Do you have documents that confirm the allegations?
• Are there witnesses who can confirm these suspicions?
   

How can you report it?

• by email: compliancebeauftragter@fritzwinter.de
• by post: Compliance Officer, Albert-Schweitzer-Straße 15, 35260 Stadtallendorf
• by telephone: 06428/78-300
• A personal meeting can also be arranged at the request of the whistleblower. With the consent of the whistleblower, this can also take place by means of video and audio transmission. 
   

You also have the option of contacting our ombudsman. The lawyer and notary Mr. Florian Möller from the law firm Immel & Möller, Stadtallendorf has been appointed as the company's external ombudsman. Employees and third parties can contact this neutral body confidentially and anonymously if they observe incorrect business practices within the company.

Mr. Florian Möller, lawyer and notary
Am Markt 6
35260 Stadtallendorf

E-mail: info@kanzlei-hoffbauer.de

Phone: 06428/3088
 

Before starting to process the report, the ombudsman will clarify the anonymity issue with the whistleblower. The whistleblower must then decide whether they wish to disclose their identity to the Compliance Office or remain anonymous. In order to be able to investigate a report carefully, it is advisable to provide personal details. Anonymity can make it more difficult to exchange information during the investigation, especially if queries to the whistleblower are necessary. 

Procedure after reporting

After reporting, the whistleblower will receive a confirmation of receipt from the reporting office, if possible, after seven days at the latest. As far as possible, the Reporting Office will maintain contact with the whistleblower, check the validity of the report received and, if necessary, ask the whistleblower for further information.

Within three months of the confirmation of receipt or, if receipt has not been confirmed, no later than three months and seven days after receipt of the report, the Reporting Office shall, as far as possible, provide feedback to the whistleblower regarding any follow-up measures planned or taken and the reasons for these. Confidentiality must be maintained. Information that could jeopardize the proceedings does not have to be communicated.

The documentation will be deleted 3 years after the conclusion of the proceedings, unless longer storage is necessary and proportionate to fulfil legal obligations.