Compliance & whistleblower protection

The HJS whistleblower system/rules of procedure for the complaints procedure

Here we offer our employees, business partners, customers or other third parties the opportunity to report observed compliance violations relating to HJS around the clock, so that legal and regulatory violations are quickly uncovered and proven misconduct is stopped. This is because violations of laws and guidelines can cause serious damage to the company, its employees, business partners and the general public.

Use our whistleblower system/complaints procedure if you have concrete indications of serious violations of applicable laws, guidelines or company principles. Serious violations are above all

• Corruption, antitrust and money laundering offenses
• Theft, embezzlement and enrichment offenses
• Violations of securities regulations and the illegal use of insider information
• Human rights or environmental risks as well as violations of human rights or environmental obligations arising from the business activities of HJS or one of our direct or indirect suppliers; a violation of a protected legal position or human rights or environmental obligation is any behavior that violates one of the prohibitions listed in Section 2 (2) and (3) LkSG
• Violations of environmental standards
• Falsification and suppression of contracts, reports or records
• Serious violations of privacy and data protection
• Misconduct relating to proper accounting, internal accounting controls, auditing and financial reporting
• Regulatory violations that could seriously damage the company’s reputation
• Violations by managers and members of executive bodies
• Abuses relating to EU law, such as tax fraud or offenses in connection with public contracts, product and traffic safety, public health and consumer protection

Protection for everyone involved:

The whistleblower system/complaints procedure guarantees the greatest possible protection for whistleblowers and those affected, among other things by the fact that it can also be used anonymously if desired. Please visit our whistleblower system: Whistleblower channel

An investigation of the facts will only be initiated after careful examination of the information and if there are concrete indications of a breach of the rules. The information is processed as part of a fair and confidential process. The name of the whistleblower or circumstances that could reveal the identity of the whistleblower are not disclosed to the accused person or the public. Disclosure of identity may only be necessary in exceptional cases, e.g. due to legal provisions. Discrimination, intimidation or hostility resulting from a report via the HJS whistleblower system/complaints procedure will be investigated and punished in accordance with the same process.

TELL US, but tell it right.

Once the information has been received, it is examined by the compliance organization – or, in the case of potentially serious violations, by the Compliance Committee established specifically for this purpose (consisting of the Chief Compliance Officer, Head of Legal Affairs, Head of Corporate Audit, Head of Human Resources) in compliance with all necessary procedural principles (e.g. confidentiality, protection of whistleblowers) and in accordance with applicable law, and the necessary measures are initiated.

Everyone involved works as efficiently as possible to investigate and solve problems. However, each investigation is different and therefore the time taken may vary. HJS endeavors to process all concerns quickly, i.e. within weeks rather than months, and to provide you with feedback on the status of the investigation after 3 months at the latest. You will receive feedback once an investigation has been completed.

In order to be able to process the case carefully and, if necessary, initiate appropriate investigative measures, regular dialog with the whistleblower is necessary. We are therefore pleased if the whistleblower provides a means of communication.

If no communication option is offered (e.g. by means of an “anonymous” e-mail address set up specifically for this purpose, etc.) because, for example, no contact address is provided for reasons of anonymity, we assume that you also consciously and implicitly wish to waive the right to receive confirmation of receipt (within seven days of receipt) for your report or (interim) notification of the results (within three months of receipt of the report). You can rest assured that we will nevertheless deal with your information appropriately.

Please bear in mind that any information you provide may lead to decisions that may have consequences for HJS employees and third parties. We therefore ask you to provide us with information that is correct and complete to the best of your knowledge and as specific as possible. It is helpful if you consider the following questions when describing the facts:Who is involved? Who is affected?

• Who is it about? Who is affected?
• What happened?
• When was the incident?
• How often did it happen?
• Where did the incident take place?

Please make sure that the descriptions are also comprehensible for non-specialists. It is helpful if you are available for further questions – even if, for example, by means of an e-mail address set up especially for this purpose.

Effectiveness test:

The effectiveness of the complaints procedure is reviewed on an ad hoc basis, but at least once a year.

Storage period of the data:

HJS stores information for as long as this is necessary for further prosecution or as long as we are obliged or entitled to do so by law.

Please use the following compliance form

As an affiliated company of DEUTZ AG, they also have access to the HJS whistleblower system also the way to the whistleblower system of DEUTZ AG is also open to you.