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What is Semperline?

Our Code of Conduct (https://www.semperitgroup.com/company/compliance-code-of-conduct) sets the tone for how we conduct business globally. Violations of laws, regulations, our Code of Conduct or other internal rules are not tolerated at Semperit. We expect and encourage all employees, suppliers, customers and other stakeholders to report any suspected violations or violations of which they have become aware.

As an employee you should initially report any possible illegal, unethical or improper conduct to your supervisor, other manager or (local) Human Resources contact. If you as an employee feel you cannot raise and resolve compliance concerns internally or if you are not an employee (customer, supplier or business partner), we provide the reporting tool “SemperLine” for your use.

This line is free of charge and may be used by any stakeholder anywhere in the world 24 hours a day and 7 days a week. We encourage you to identify yourself in order for us to set the best possible parameters for an effective investigation, but if you wish, you can report concerns anonymously. If you decide to remain anonymous, we offer you the opportunity to set up a secured postbox to communicate with us. This enables us to contact you in case additional questions arise. We will provide you with feedback.

All reports are received and processed according to a standardised process. Only you and the relevant Semperit Compliance team can access your report. All the information which is provided and case investigations, including the identity of the whistleblower, will be handled discreetly and in strict confidence. Only provide and submit information that is true and complete to the best of your knowledge.

Why should I submit a report?

At Semperit, we conduct our business with integrity and in line with our corporate values.

You may have concerns or may be aware of harmful behaviour that puts Semperit at risk. Your report will enable us to detect integrity and compliance issues at an early stage and help us to address your concerns as soon as possible. Your report enables us to protect Semperit from a wide range of dangers and risks. This allows us to remain efficient and successful in our long-term business activities.

Which incidents can be reported?

You can report any violations of laws, regulations our Code of Conduct or internal guidelines. SemperLine allows you to select from a range of reporting categories during the reporting process. If the content of your report does not fall under one of the proposed categories, please choose the category “Other violations and misconduct”.

Compliance-related concerns and information about any violations should be described in as much detail as possible. It is helpful if your report covers the following five questions: “Who? What? When? How? Where?”. You can also upload documents, images or videos.

Only provide and submit information that is true and complete to the best of your knowledge. The information you provide can lead to decisions that will have serious consequences for the people who are involved. Knowingly providing false or misleading information is prohibited by law. Do not share any information under any circumstances if this is unlawful in your country, including state secrets.

What is the process for submitting a report?

To submit a report with your name or anonymously, start by clicking the “Submit Report” button, which is located on the top left side of our introduction page. We encourage you to identify yourself by stating your name.

The reporting process consists of four steps:

1. You will be asked to review information concerning the protection of your anonymity and answer a security question.
2. On the following page, you will be asked to select the category of your report.
3. On the report page, you can provide detailed information about the incident(s) / violation(s) and answer questions about them by simply selecting responses. The free text field allows you to write up to 5,000 characters, which equates to a full A4 page. You may also submit a file of up to 5 MB in size. Please bear in mind that documents may contain information about their author. After you have submitted your report, you will receive a reference number to confirm the successful submission of your report.
4. After that, you will be asked to set up your own secured postbox. This postbox enables us to provide feedback to you, answer your questions and notify you about the report status.

Once you set up your secured postbox, you can access it directly via the “Login” button. First, you will have to answer a security query.

As long as you do not enter any data about yourself which can be traced back to you, or could reveal your identity, the certified BKMS^® System system will protect your anonymity using technical measures.

Please rest assured that we are only interested in the matter you are reporting. Malpractice must be uncovered and any (additional) damage prevented.

How is my anonymity protected and how do I receive feedback?

The SemperLine system protects people who submit a report and who do not wish to reveal their identity. The system’s anonymity protection function has been certified by an independent body.

When setting up your secured postbox, please select your own pseudonym/username and password. Your report will be kept anonymous using encryption and other special security measures. You will never be asked for personal information at any time during the reporting process. Do not submit any information that can be traced back to you. In order to avoid your identity to be tracked outside the Semperline system, do not use a computer provided by your employer to submit your report. Using an Semperit intranet connection, in particular, may jeopardise your anonymity.

The Semperit Compliance team will contact you via the secured postbox and give you feedback about the processing of your information or ask you questions if any details in your report are still unclear. You may remain anonymous during the dialogue.

We encourage you to identify yourself in order for us to set the best possible parameters for effective examination and investigation of your report. If the person submitting the report provides their name, the examiner can then contact them directly. If you do not wish your details to be shared outside of the Semperit Compliance team, please indicate this in your report. Information on the handling of the personal data you share with us can be found here. Please note that we are only interested in the information provided in the report to prevent any damage and not in you as a whistleblower.

Data protection

Personal data is processed by Semperit exclusively according to the applicable data privacy regulations for the purpose of operating a whistleblowing system and investigating reports submitted via this system.

The whistleblowing system SemperLine enables the secure and confidential transmission, collection and processing of reports concerning violations of regulations which apply at Semperit. Access to the data is only granted to a small number of expressly authorised legal consultants and employees at Semperit, who are subject to strict confidentiality obligations. Neither EQS Group GmbH nor other third parties have access to the data.

Semperit employees can find additional information about reporting malpractice and the process for doing so in the internal whistleblowing guideline. Detailed information on data protection and processing can be found here.

How does Semperit evaluate my report?

All reports are received and processed exclusively by Semperit according to our standardised process. All information which is provided will be handled discreetly and in strict confidence. The information will only be shared with people who are responsible for the further examination and investigation of the case.

The Semperit Compliance team processes and reviews your report and decides whether an in-depth internal or external investigation is required. If your report requires further examination, we may forward it to departments which are responsible for handling the case which is detailed in the report. During this process, the individuals involved in the case are given the opportunity to comment on the case you have reported to us. If you disclosed your name in your report and you do not wish us to share this information with individuals involved in the case during our investigation, please indicate this in the report. The information contained in the report may also be disclosed to state authorities if necessary and required by law.

We will use your postbox, which you have set up within the system, to inform you about the outcome of your report, but we will not communicate details about results of the investigation and measures which have been taken, as data protection and, depending on the case, other legal provisions may apply.

What do I do if I am subjected to retaliatory measures?

We understand that you may be uncomfortable or scared about speaking up when something is not right. That is why we prohibit retaliation. We have processes in place to protect anyone who raises a concern in good faith or cooperates in an investigation against any form of retaliation. You can notify the Compliance team directly if you believe that you have been subject to retaliation (compliance@semperitgroup.com) or you can use SemperLine by selecting the “Other violations and misconduct” category. It is unlawful to knowingly provide false or misleading information.