Reporting channel for
whistleblowers.

The German Whistleblower Protection Act (Hinweisgeberschutzgesetz, HinSchG) has been in force since 2 July 2023. It protects people who report breaches they have learned about in a work-related context. TRiALED operates an internal reporting channel for this purpose.

It matters to us that problems reach us before they cause damage. A report is not a sign of distrust – it helps the company.

The reporting channel is open to everyone who is or has been in a work-related relationship with TRiALED:

• Employees, apprentices and temporary agency workers
• Applicants and former employees
• Self-employed people, suppliers, service providers and their employees
• Shareholders as well as members of management and supervisory bodies

The reporting channel covers breaches that fall within the scope of section 2 HinSchG. These include in particular:

• Criminal offences
• Regulatory offences, where the provision breached serves to protect life, limb or health, or the rights of employees
• Breaches of rules on product safety, environmental protection, public procurement, data protection, competition and the further areas listed in section 2 HinSchG

For matters outside this scope – questions about day-to-day work, orders or complaints, for example – please contact your usual contact person or write to info@trialed.de. The reporting channel is not a general complaints desk.

You can submit your report in writing or in a personal conversation.

In writing by post:
TRiALED GmbH
Internal reporting channel
An der Pönt 46
40885 Ratingen, Germany

Please mark the envelope “Confidential – to be opened by the reporting channel only”. It will then be passed on unopened.

Personal conversation:
On +49 30 4397929208 you can arrange an appointment with the reporting channel – away from company premises if you prefer. At your request the conversation will be documented; you will receive that documentation to check and confirm.

You do not have to give your name. Reports received anonymously are processed as well.

Please bear in mind: without a way to contact you we cannot ask follow-up questions or give you feedback, which makes investigation harder. If you give us a way to reach you, we treat it in strict confidence.

The reporting channel follows fixed steps:

• You receive confirmation that your report has arrived within seven days.
• The reporting channel checks whether the breach falls within scope and stays in contact with you.
• It assesses the validity of the report and takes appropriate follow-up action.
• Within three months of the confirmation of receipt you receive feedback on the measures planned and already taken. Where the assessment is extensive this period may be longer; we will tell you if that happens.

Your identity is protected. Only the people running the reporting channel learn who submitted the report. The same applies to the identity of the people the report concerns and of anyone else named in it.

Confidentiality may only be lifted in the exceptional cases set out in law, for example at the request of law enforcement authorities (sections 8 and 9 HinSchG). We will inform you beforehand where that does not jeopardise the investigation.

Retaliation against whistleblowers is prohibited (section 36 HinSchG). No one may be dismissed, warned, transferred, passed over for promotion or otherwise disadvantaged because of a report. This also applies to attempts and threats.

If a whistleblower suffers a disadvantage after making a report, the law presumes that this is retaliation. Protection applies where, at the time of the report, you had reasonable grounds to believe that your information was true.

Anyone who intentionally or through gross negligence reports incorrect information is liable for the resulting damage (section 38 HinSchG) and is not protected. A report made in good faith that turns out to be unfounded, by contrast, has no consequences for you.

You can also turn directly to an external reporting channel. An internal report is not a precondition.

• Federal external reporting channel at the Federal Office of Justice: https://www.bundesjustizamt.de/hinweisgeberstelle
• Federal Financial Supervisory Authority (BaFin) for breaches in the financial sector: https://www.bafin.de
• Federal Cartel Office for breaches of competition law: https://www.bundeskartellamt.de

Reporting channels at institutions, bodies and agencies of the European Union are available in addition.

Public disclosure is protected only under the narrow conditions of section 32 HinSchG.

The reporting channel processes personal data only as far as necessary to handle the report. The legal basis is Article 6(1)(c) GDPR in conjunction with section 10 HinSchG.

Every report is documented in a permanently retrievable form. The documentation is deleted three years after the procedure has been closed, unless longer retention is required by law (section 11 HinSchG).

Further information on how your data is processed and on your rights can be found in our privacy policy.