This policy describes the procedure for reporting confirmed or suspected malpractice or misconduct. It applies to all employees, customers, suppliers of syracom AG and anyone with an interest in the well-being of the Company.
We encourage anyone who has knowledge or reasonable suspicion of material misconduct (violation of law or unethical conduct contrary to our Code of Conduct) to make a report. Through the whistleblower system with legal expertise of Ratisbona Compliance, reports are made directly to Ratisbona Compliance GmbH. Reports can be made digitally via the Ratisbona Compliance reporting platform, by telephone or in person. This is intended to enable significant misconduct and grievances to be resolved while maintaining the highest possible level of confidentiality.
Any perceived grievances can be reported via the whistleblower system, accessible via the legal notice on the syracom homepage. After an initial review by Ratisbona Compliance, a further exchange takes place between the whistleblower and Ratisbona Compliance. If the whistleblower agrees, Ratisbona Compliance then provides a legal assessment and recommendations for action for reporting to syracom. Internal company investigations then take place in order to make an internal company decision on how to proceed. syracom informs Ratisbona Compliance of this decision. Ratisbona Compliance then informs the whistleblower in due time about planned and already taken follow-up measures as well as the reasons for these.
Intentional misreporting will be considered a violation of the Code of Conduct and will be treated accordingly.
Through the whistleblower system of Ratisbona Compliance, anonymous communication with the whistleblower is possible and ensured if required. Upon receipt of a report of alleged misconduct or fraudulent behavior, the facts of the case are subjected to an initial review based on the information contained therein. When an electronic report is submitted via the reporting plattform, a case number is generated, which can also be used to ask the reporting Party questions to further asses the matter while maintaining anonymity. Ratisbona Compliance shall assume responsibility for the timely review and processing of incoming reports. Based on this initial assessment, the further course of action to deal with the matter is determined. Depending on the seriousness of the allegation, the group of persons affected and the area of law, the report will be passed on to the responsible unit of the relevant shareholding or shareholding group. External experts may be called in for further examination of the misconduct. There may be a duty to report if there is sufficient suspicion of a criminal offense. Ratisbona Compliance shall ensure that all reported cases are investigated and concluded with sufficient documentation. syracom expects managers and supervisors at all hierarchical levels to take such reports seriously, to treat them in strict confidence and to resolve them promptly with the appropriate guidelines and necessary measures to eliminate the malpractice (outcome-oriented).
Ratisbona Compliance GmbH may conclude that a report will not be followed up, for example, if
Reporting is carried out by the legal department of Ratisbona Compliance. Reporting is done in detail for the cases investigated by Ratisbona Compliance.
No one who makes a report will suffer any negative consequences as a result. However, reporting parties (as whistleblowers) also enjoy no protection in the event of misconduct. The identity of all Reporting Parties will be kept absolutely confidential. Ratisbona Compliance will under no circumstances disclose voicemails, IP addresses and/or telephone numbers, unless one of the exceptions under this chapter is applicable. In the following cases, whistleblower protection is not guaranteed:
If the reporter does not agree with the result of the investigation, he/she again has the possibility to make this known via the whistleblower system with legal expertise of Ratisbona Compliance GmbH.
If investigations are initiated as a result of a report, syracom will inform the parties concerned within 30 working days at the latest. This phase may also be extended under consideration of the case-specific situation, e.g. if there is a risk that evidence will be destroyed or that the initiated investigations will otherwise be impeded. Data subjects have the right to complain about investigations directed against them. For this purpose, data subjects shall contact the Ratisbona Compliance GmbH.
Ratisbona Compliance will treat all information as strictly confidential. The protection of data of both reporting parties and affected parties is assured within the legal framework. Information will be made available on a restricted basis, both in terms of content and the group of persons concerned (so-called "need-to-know basis"). This policy requires the processing and storage of personal data. This is done exclusively in accordance with data protection regulations.