Whistleblower System, Hinweisgebersystem

Compliance

For us, compliance means consistently adhering to legal and internal requirements. Our Code of Conduct, our compliance officers, and our confidential whistleblower system provide guidance and support in this regard. In this way, we uphold our high standards and strengthen the trust of our partners in research and business, as well as our employees, in our commitment to acting with integrity.

For us, compliance means consistently adhering to legal and internal requirements. Our Code of Conduct, our compliance officers, and our confidential whistleblower system provide guidance and support in this regard. In this way, we uphold our high standards and strengthen the trust of our partners in research and business, as well as our employees, in our commitment to acting with integrity.

Compliance - gears concept - 3D illustration

Code of Conduct

Below is our Code of Conduct, which sets forth our core values and principles. Internally, it serves as a binding guide for responsible and ethical conduct in our day-to-day work. At the same time, it also serves as a guideline for our collaboration with our business partners in research and industry.

See our Code of Conduct

Our Whistleblowing System & Complaint Management

As a public-sector company, we have always positioned ourselves clearly in favour of acting in accordance with the law, as this is the only way to ensure sustainable success for us all. Compliance with laws and internal policies is our top priority.
In order to identify and remedy misconduct (e.g. corruption, human rights violations, fraud) at an early stage, we have set up a qualified internal reporting office. This also includes complaints regarding possible risks or (attempted) violations within the scope of our responsibility for our supply chain.

We encourage all employees and business partners to report any information regarding compliance-related (suspected) cases primarily through this specialized system. It enables secure and confidential communication - which can also be anonymous, if desired - with our independent experts.

Of course, managers and the management team are still available to adress general concerns and complaints arising from day-to-day work. Various internal contact points and designated representatives are primarily available for this purpose (see above). Details can be found on the intranet. If managers or members of executive management receive reports of compliance violations, these reports will be forwarded to the appropriate reporting office – primarily the internal reporting office – for an objective investigation and to ensure confidentiality. Whistleblowers are protected from retaliation in all cases.

You also have the option of using external reporting procedures, although you should prefer internal reporting if effective action can be taken against the violation internally. Information on external reporting procedures can be found on the homepage of the Federal Office of Justice (BfJ).

These external reporting offices will approach you with an acknowledgement of receipt and point out the possibility of reporting to our internal reporting office. If, after examining your report, the external reporting office comes to the conclusion that it falls within the scope of the Whistleblower Protection Act and that the allegation is valid, then they can contact our company to clarify the facts. If the external reporting office is not competent or if the external reporting office cannot investigate the reported violation within a reasonable period of time, it will pass it on to the competent prosecution authorities. Minor violations are often not prosecuted by the authorities.

In order to be able to uncover misconduct quickly and to stop a violation immediately, we therefore ask you to use our Internal Reporting Office as a matter of priority. This will help your colleagues and Helmholtz Munich.

Where can I report my Hint?

For whistleblowing purposes only, Helmholtz Munich has set up a web solution with a QR code and a telephone hotline where all employees and business partners from the research and business communities (e.g. collaboration partners, service providers, suppliers, etc.) in particular can report operational legal violations or human rights and environmental risks openly, either by name or anonymously.

Web solution: https://app.whistle-report.com/report/da71fc05-56d9-4dce-a751-5a52cf8cc23e

Telephone hotline: +49 69 99998839 (Monday to Friday from 9 a.m. to 5 p.m.)

Every report is carefully investigated.

 

Who can provide Hints?

The whistleblower system can be used by all employees, including trainees, temporary workers and freelancers. In addition, the whistleblower system is available to all third parties, such as guests and business partners from the research and business communities (e.g. cooperation partners, service providers, suppliers etc.).

What kind of Hints can I give?

(1) Reports of questionable, unusual accounting, auditing, banking and other monetary practices, which may significantly affect the interests of the Helmholtz Munich and may directly or indirectly lead to damage or other detriment to Helmholtz Munich or third parties.

(2) Reports related to internal accounting controls, corrupt practices and financial crimes.

(3) Other grievances at Helmholtz Munich or (suspected) violations of internal guidelines (e.g. Code of Conduct, Guideline Corruption Preventionn, Policy on Courtesies and Hospitality).

(4) Hints on human rights or environmental risks and violations of human rights or environmental obligations in Helmholtz Munich's own business area and along the supply chain.

(5) Actual or attempted violations of legal requirements (e.g. criminal offences such as fraud, bribery, corruption, theft, the granting or acceptance of undue advantages, as well as violations of laws in general, such as the German Federal Travel Expenses Act).

Who receives and processes my Hint?

Upon receipt of a report submitted through the whistleblowing system, the system notifies both the reporting person and an external attorney of the receipt of the report.

The external attorney then informs the Compliance Officer of the receipt of the report. The report is initially handled by the external attorney. Following a review of the report, the external attorney provides the Compliance Officer with a preliminary assessment and a recommendation for further action.

The Compliance Officer reviews the prepared report and the recommended course of action and assumes responsibility for handling the report. Where necessary, the Compliance Officer may involve other members of the investigation team or the investigation team as a whole.

If case-specific complaints offices or designated officers (e.g. the Commission for Matters of Good Scientific Practice) exist or have been appointed at Helmholtz Munich, the reporting person will be referred by the external attorney to the competent complaints office or designated officer. A referral to the competent complaints office or designated officer will not be made if that office or person is themselves affected by or involved in the reported matter.

Where necessary, the Compliance Officer, other members of the investigation team, or the investigation team as a whole (see the following sections below) may be called upon by the complaints office or designated officer to provide support.

Who is a Member of the Investigation Team?

Members of the investigation team are:
   
    the Compliance Officer, Dr. Nikolaus Ukert; deputy Fabian Zarzitzky
    the Head of the Human Resources Department, Michael Deeg
    the Head of the Internal Audit Department, Cristina Petersen
    the Head of the Legal Affairs Department, Karina Blasius
   

What happens if my Hint is directed against a Member of the Investigation Team or against the Management?

In cases where the report concerns one or more members of the investigation team, the external attorney shall notify at least one member of the Management directly.

If the report concerns one of the members of the Management, the other permanent member of the Management shall be informed.

If the report concerns the entire Management, the Chair of the Supervisory Board shall be informed directly by the Compliance Officer or, where appropriate, by the external attorney.

How will I be protected?

Helmholtz Munich encourages openness and supports individuals who report concerns, even if a report subsequently proves to be unfounded. Reporting persons need not fear any disadvantages as a result of reporting actual or suspected misconduct.

Anyone who believes that they have been subjected to a disadvantage or retaliation should promptly inform the Compliance Officer. If the matter cannot be resolved in this way, a formal complaint should be submitted to the Executive Management of Helmholtz Munich.

Reporting persons must neither be threatened nor subjected to any form of retaliation. Any person involved in such conduct may be subject to employment-related disciplinary measures. In certain cases, reporting persons may also have the right to seek compensation by bringing a claim before the competent labour court.

What are the Consequences if I knowingly provide false or misleading Information?

Conversely, if Helmholtz Munich determines that a reporting person has knowingly made false allegations, the reporting person may be subject to employment-related disciplinary measures.

Accordingly, no protection is afforded to reporting persons who knowingly provide false or misleading information. This may result in the disclosure of the reporting person's identity (provided that the reporting person disclosed their identity when submitting the report), as well as disciplinary action or even civil or criminal liability.

Nevertheless, a reporting person will not lose protection merely because a report made in good faith subsequently proves to be inaccurate or unsubstantiated.

When will I receive Feedback?

The reporting person will receive feedback within seven days that a report has been received.
Within three months, the reporting person will receive information about the measures taken, the status of the internal investigations and their results. However, the time frame can be extended to six months if this is required by the special circumstances of the case, in particular if the nature and the complexity of the subject matter of the notification entail a lengthy investigation. 

Compliance and anti-corruption officer Nikolaus Ukert will continue to be available at any time to answer questions about the whistleblower system, the topic of compliance and anti-corruption at antikorruption@helmholtz-munich.de.