NewRe’s Whistleblowing Portal - Report Concerns

Who can report?

Anyone can report. This includes but is not limited to our own employees, our customers/clients, suppliers and other business partners as well as the general public. Anyone who decides to report is generally referred to as a “Whistleblower”.

What can be reported?

Reports may cover potential compliance violations (which occurred or are very likely to occur) relating to, among others:

• Corruption / Bribery
• Other white-collar crime (fraud, embezzlement, etc.)
• Data Protection
• Antitrust / Competition
• Insider Trading / Market Manipulation
• Regulatory
• Anti-money laundering (AML)
• Sanctions
• Conflicts of interest
• Information Security
• Human Rights or other ESG aspects
• for NewRe employees: Discrimination / harassment / violation of labour law

as well as other topics that do not necessarily fit into any of the abovementioned categories or that defeat the object or the purpose of any underlying rules or regulations (statutory or internal).

Where can I report?

You have reached NewRe’s whistleblowing channel. NewRe has implemented this secure and confidential whistleblowing system.

You can access the whistleblower platform from anywhere in the world and at any time.

If you are an employee of NewRe, you may of course also turn to your superior, the HR department or the NewRe Legal & Compliance department if you become aware or are suspicious of circumstances relating to compliance. The Legal & Compliance department, who is bound to maintain confidentiality, is also available insofar as the protection of personal data is concerned.

Who can I address my report to?

If you are an employee of NewRe: You can choose to file your concerns with the Legal & Compliance department or only with the Head of Legal & Compliance, or the Chairperson of NewRe’s Audit & Risk Committee. Your report will only be visible for those persons with whom you want to share the information.

If you are an external whistleblower:
You report to NewRe’s Legal & Compliance department

How can I report something, how do I set up a postbox?

To submit an anonymous or personalised report, start by clicking the ”Submit report“ button located at the top of the introduction page.

The reporting process consists of five steps:

1. First, you will be asked to read some information on the protection of your anonymity and to respond to a security query.
2. On the following page, you will be asked about the category of your report.
3. You will then be asked whether you are an employee of NewRe or an external whistleblower.
4. Employees can then choose to report either to the Head of Legal & Compliance, the Legal & Compliance department or to the Chairperson of the Audit and Risk Committee.
5. On the report page, you can elaborate in your own words and answer questions about the incident by simply selecting responses. In the free text field, you can write 5,000 characters, which corresponds to a full DIN A4 page. Please note that you can phrase your report in any language. You may also upload a smaller file of up to 5MB to support your report. Please remember that documents can contain information about their author. After you have submitted your report, you will receive a reference number as proof that you submitted this report.
6. Finally, you will be asked to set up your own secured postbox. You will receive feedback from us via this postbox, we will answer your questions and keep you posted on the status of your report. We therefore encourage you to set up the protected mailbox function as this will also allow the responsible person to contact you in case there are any questions.

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

You can choose to report anonymously or by name.

If you decide to report anonymously, please make sure to not include any information that could allow conclusions to be drawn about your identity. As long as you do not enter or attach any information that could reveal your identity, BKMS^® protects your anonymity from a technical perspective.

Should you decide to give your name, we guarantee that your identity will only be disclosed to those persons directly concerned with processing the case. Once processing of the case has been concluded, your personal data will be deleted again.

What happens after my report is filed? Do I receive feedback?

The responsible person will follow up on your report, i.e. review the information and where required commence an investigation.

Provided you have chosen to include a communication channel via which the responsible person can contact you (e.g. the protected mailbox function within the whistleblowing platform), you will also receive an acknowledgment of receipt of your report within seven days and further feedback no later than three months following your report.

We therefore encourage you to set up the protected mailbox function within the whistleblowing platform as this will also allow the responsible person to contact you in case there are any questions.

How can I receive an answer, yet at the same time remain anonymous?

The principle of BKMS^® is to protect the Whistleblower's identity. The system's anonymity protection function is certified and can be verified by you at any time.

When setting up your secured postbox, you should choose your pseudonym/user name and password yourself. These login credentials are not visible for anyone but yourself. If you lose your login details, please submit a new report and set up a new postbox. If possible, please provide the reference number of your initial report. As this will be a new postbox, you cannot see the content of your previous report.

Encryption and other special security methods ensure that your report remains anonymous at all times. At no time during the process will you be asked for personal information. If you wish to remain anonymous, please do not submit any information that can be traced back to your personal identity. Also, please do not submit your report on a PC provided by your employer.

The person in charge of your report will contact you via your secured postbox to provide information about the status of your report or to ask further questions if certain details need to be clarified - your anonymity will be always protected during this process (unless required, e.g. by law).

Is my report confidential/anonymous?

Yes, your report is confidential!

You can choose to report anonymously or by name.

Should you decide to give your name, we guarantee that your identity will only be disclosed to those persons directly concerned with processing the case. Once processing of the case has been concluded, your personal data will be deleted again.

If you decide to report anonymously, please make sure to not include any information that could allow conclusions to be drawn about your identity.

Either way, confidentiality and the protection of you as a Whistleblowers is the top priority and guiding principle of our whistleblowing system and all reports will be handled on a strict “need to know” basis. Your report will only be visible for those persons with whom you want to share the information.

Do I have to fear retaliation for my report?

No!

As long as you had reasonable grounds to believe that the information reported was true at the time of your report, you may not suffer any retaliation as a consequence for your report and any attempted retaliation would in itself be considered a severe compliance violation. Vice versa, if you deliberately make a false report, this would also qualify as a severe compliance violation and may have serious consequences under criminal and labour law.