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During the use of BKMS^® System, a text file (called a “session cookie”) is saved on your computer containing only the number of your session. This is necessary for technical reasons in order to establish the connection to a security-certified server. The “session cookie” does no damage to your computer, it does not access your data and has no relation to the contents of your report. If you close all browser windows after submitting your report, the “session cookie” will expire and be automatically deleted.

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If you would like to send your first report, please click here:

If you have already set up a postbox, you may login here:

Integrity and trust are the foundation of our business.

Welcome to the whistleblowing portal of the WTS Group.

Since its founding in the year 2000, WTS has developed into a leading international consultancy. Integrity and trust are key pillars of our success. These values guide our relationships with clients and business partners as well as our internal culture.

We are therefore committed to reliably ensure compliance with all applicable laws, regulations and internal rules within the scope of our business operations. We have a pronounced interest in learning about any existing malpractices at an early point in time in order to respond to violations and protect our company from detrimental consequences.

With this whistleblowing portal, we would like to enable and encourage you to report serious known or suspected compliance violations via a secure communication channel. You are welcome to do this entirely anonymously and by setting up a secure postbox. Reports can be submitted in the categories of money laundering law, data protection, IT and information security, personnel-related matters and other crimes and compliance violations. It is also possible to submit inquiries concerning compliance topics. All incoming reports are handled with the strictest confidentiality; please also note our information on data protection.

In the sole interests of better readability, male pronouns are uniformly used in this portal.

Why should I submit a report?

Why should I submit a report?

You may have concrete knowledge of irregularities, risks or rule violations that could endanger WTS. In such a case, your report helps us to investigate the relevant circumstances at an early point in time and avert possible damage to the assets or reputation of WTS. In this way, you make an active contribution to the success of WTS and to securing our jobs.

What kinds of notifications can I submit?

What kinds of notifications can I submit?

You can submit reports on possible serious violations of laws, regulations or WTS-internal rules that fall within various categories. Additionally, you have the opportunity to use this secure system to submit a confidential inquiry concerning a compliance topic.

Detailed information on the various report categories is provided during the reporting process.

What is the process for submitting a report? How do I set up a postbox?

What is the process for submitting a report? How do I set up a postbox?

To submit a report either by name or anonymously or to make an inquiry, start by clicking the “Submit Report” button located at the top of our introduction page.

The reporting process consists of 4 steps:

First, you will be asked to read the information on the protection of your anonymity and to answer a security query.
On the following page, you will be asked about the category of your report.
On the report page, you can elaborate on your report in your own words and answer questions about the case by selecting responses. In the user-defined text field, you can write 5000 characters, which corresponds to a full DIN A4 page. You may also submit a file to support your report (maximum size 5 MB). Please bear in mind that documents may contain information about the author. Following the submission of your report, you will receive a reference number to confirm that you have sent this report.
Please subsequently set up your own secured postbox. You will receive feedback from us and information about the progress of your report via this postbox, and you can also use it to answer questions.

If you already have a secured postbox, you can access it directly via the “Login” button. Again, you will have to answer a security query first.

How do I receive feedback and remain anonymous at the same time?

How do I receive feedback and remain anonymous at the same time?

The overriding principle of the BKMS^® procedure in use is the protection of the whistleblower. The system's anonymity protection function is certified by an independent body.

When setting up your secured postbox, you select your own pseudonym/user name and password. Your report is kept anonymous through encryption and other special security measures. You will never be asked for personal information at any time during the reporting process. As long as you do not enter any data from which conclusions about your person can be drawn, the technology of the BKMS^® System will protect your anonymity. In addition, you can protect you anonymity by using a personal or a public device.

Via the secured postbox, a person dealing with will give you feedback about the further processing of your report or may ask you questions if some details are still unclear. The BKMS^® System protects your anonymity also during this dialogue. We are interested in reports to avoid damage, not in you as a whistleblower.

Information on data protection

Information on data protection

In the following we would like to inform you on the collection, processing and use of personal data within the whistleblowing system of WTS. WTS or WTS Group refers to WTS Group AG with its seat in Munich, Germany, as well as all other companies in which this parent company directly or indirectly holds a majority interest.

We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 - hereafter “GDPR”) as well as current national data protection regulations. Please read this privacy information carefully before submitting a report.

Purpose and legal foundations of the whistleblowing system

The whistleblowing system serves the purpose of receiving and processing reports concerning possible violations of laws, regulations or internal rules of WTS Group via secure and confidential channels. We observe the principle of restricting the use of personal data to specific purposes, and we only process personal data for the purposes that are described in this privacy statement.

The processing of personal data within the framework of the whistleblowing system is based on our legitimate interest in the discovery and prevention of malpractice and the associated averting of damages and liability risks for WTS Group (Section 6 para. 1 item 1 point f GDPR in connection with Sections 30, 130 Code of Administrative Offences (“Ordnungswidrigkeitengesetz” / “OWiG”)).

According to Section 6 para. 5 of the German Act on Tracing Profits from Serious Crimes (Money Laundering Act – “Geldwäschegesetz” / “GwG”), we are obligated to take reasonable measures to enable our employees and persons in a comparable position to report violations of anti-money laundering obligations and regulations to suitable parties while ensuring the confidentiality of their identity (Section 6 para. 1 item 1 point c GDPR).

If a received report concerns an employee of WTS, the processing also serves to prevent criminal acts or other infringements in connection with the employment relationship (Section 26 para. 1 German Federal Data Protection Act (“Bundesdatenschutzgesetz” / “BDSG”)).

Responsible authority, data protection officer and data security

The party responsible for data protection in the whistleblowing portal is

WTS Group AG
Friedenstraße 22
81671 Munich
Germany

Tel.: +49 (0) 89 286 46-0
Fax: +49 (0) 89 286 46-111
e-mail: info@wts.de

WTS Group AG is represented by its Board Members: StB Fritz Esterer Dipl.-Oec. (Chairman), WP StB Franz Prinz zu Hohenlohe, StB Ulrike Schellert, StB Jürgen Scholz.

The Group data protection officer of WTS is:

RA Prof. Thorsten B. Behling
WTS Group AG
Sachsenring 83
50677 Cologne
Germany
e-mail: thorsten.behling@wts.de

The whistleblowing portal is operated on behalf of WTS Group AG by a specialised company: EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin, Germany.

All data in the whistleblowing portal are secured by extensive technical and organisational measures, in particular encrypted to ensure that EQS Group GmbH does not have access to the data, and only WTS more specifically persons appointed by WTS can access the data.

Confidential handling of reports, sharing and recipients of data

Incoming reports are received by selected, specially trained and thus unbias and independent employees of WTS. They are the only persons who have access to the data stored in the whistleblowing portal. The designated employees assess the situation and conduct further investigations, if necessary.

During the processing of submitted report, it can be necessary to share reports with additional employees or offices within WTS or other WTS Group companies, e.g. if a report refers to activities in a subsidiary of WTS Group AG. If there is sufficient reason to suspect a crime, data and information from the reporting process may be shared with a law enforcement agency for the purpose of initiating further investigations and possible penalties. The offices mentioned above and other recipients may be based in countries outside the European Union or the European Economic Area with different regulations regarding the protection of personal data.

In certain cases, we are obligated by data protection law to inform an accused person that we have received a report concerning them. The identity of the whistleblower will not be disclosed – insofar as this is legally permissible – and it will also be ensured that it is not possible to draw any conclusions concerning the identity of the whistleblower.

We will always ensure that the applicable data protection regulations are complied with when sharing reports.

The follow-up of received reports always takes place in strict confidentiality. In general, your name or any circumstances that could reveal your identity as a whistleblower are not mentioned, unless this is absolutely necessary in exceptional cases, such as due to statutory regulations.

The honest use of the whistleblowing portal will not have any adverse consequences for you as a whistleblower. In the case of abuse, such as the deliberate submission of false reports with the intent of discrediting an individual, we reserve the right to take action against the whistleblower.

Categories of personal data that we process

The data categories depend on the decision for or against an anonymous report submission and which data on persons are shared in the report. To satisfy the purposes listed above, the listed types of personal data and data categories are collected, processed and used insofar as such data – in particular – are provided to us in the whistleblowing system:

Basic personal data (e.g. salutation, title, first name, last name)
Contact data (e.g. e-mail address, telephone number, possibly fax number)
Company information (e.g. name of the company, department, location)
Address data (e.g. street, postal code, city, country)
Report contents

Sources of personal data that we process

In the course of operating the whistleblowing system and the processing of data in this system, we receive and collect any personal data only from the whistleblower himself in the form of his report.

Storage period

The received personal data are stored only as long as is necessary to satisfy the respective purpose of the storage (see above). If this purpose no longer applies, we will delete or anonymise the data provided and to the extent that no legitimate reasons or obligations to retain the data exist. In the later case, the data are only processed to a limited extent, in other words only to satisfy the retention reason or obligation and otherwise only with consent, for asserting, exercising or defending legal claims, for protecting the rights of another natural or legal person or for reasons of an important public interest of the European Union (EU) or an EU member state. If a retention obligation exists, we will delete or anonymise the data once the retention obligation definitively no longer exists.

Use of the whistleblowing portal

Communication between your computer and the whistleblowing portal takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the whistleblowing system. In order to maintain the connection between your computer and the BKMS^® System, a cookie is stored on your computer that merely contains the session ID (a so-called session cookie). This cookie is only valid until the end of your session and expires when you close your browser.

It is possible to set up a postbox within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the respectively responsible employee at WTS anonymously or by name, if desired. This system only stores data inside the whistleblowing system, which makes it particularly secure. It is not a form of regular e-mail communication.

Your visit to the whistleblowing portal may still leave traces on your computer. If you are accessing the whistleblowing portal from a WTS computer, you might want to clear the temporary files (cache) afterwards.

Rights of the data subjects

Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure, restriction of processing and right to object to the processing of your personal data. If the right to object to the processing of the personal data is exercised, the necessity to store the data, especially for processing a report, will be evaluated immediately. Data that are no longer needed will be deleted at once.

Additional information and an opportunity to assert your rights can be found on the website: https://www.wts.com/de-de/datenschutz

In addition, you can submit a complaint at any time to the competent data protection authority, such as at your place of residence or the location of the alleged violation.

The following data protection supervisory authority has jurisdiction over WTS:

Data Protection Authority of Bavaria
Promenade 27
91522 Ansbach, Germany
https://www.lda.bayern.de

Note on sending attachments

When submitting a report or an addition, you can simultaneously send attachments to the responsible WTS employee. If you wish to submit an anonymous report, please take note of the following security advice: files can contain hidden personal data that could endanger your anonymity. Remove this data before sending. If you are unable to remove this data or are uncertain about how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.

Status and modifications to this information on data protection

This information on data protection is current as of the date given below. This information is subject to change. We therefore ask you to regularly look at the information on data protection in order to be informed of any changes.

Version: August 2023

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