Corporate Governance
Whistleblower System for Compliance Violations and Complaints Office for Violations of Human Rights-related or Environmental Obligations
The economic success of KAP AG and its subsidiaries (thereafter "KAP Group") is based on performance, quality and the trust that business partners and shareholders place in us and our activities. Lawful and ethical behavior both internally and externally, honest and fair communication and interaction with each another comprise the basis for this success.
We summarized some time ago the major principles of ecologically, socially and ethically responsible corporate governance and integrity in a Code of Conduct of KAP Group, which – together with other policies and procedures – represents an important basis for successful future collaboration within the entire KAP Group. At the same time, we also follow the recommendations of the German Corporate Governance Code, especially the Principle 5, Recommendations and Suggestion A.2, according to which employees and third parties should be given the opportunity to report on any violations of law and compliance issues in a protected manner. This has been specified in the EU Whistleblower Directive and the Whistleblower Protection Act. We want to fully comply with this requirement, as this corresponds to an open corporate culture which we feel committed to.
It is in the interest of the KAP Group and thus also in the interest of all employees that compliance irregularities and misconduct are avoided. An attitude of integrity and the awareness of each individual make an important contribution to this process. At the same time, the KAP Group is interested in becoming aware of any compliance violations and violations of human rights or environmental obligations in order to avert a possible damage to the Group or third parties. We would therefore like to encourage all employees, but also our business partners, suppliers and other third parties, to contact the responsible departments in the Group if they suspect any misconduct. This channel of communication can be the Central Compliance Function or the Human Rights Officer of KAP AG (e-mail: compliance@kap.de). You can also contact our Ombudsman confidentially, who also acts as an internal whistleblower system of behalf of KAP Group.
The ombudsman of the KAP Group is:
Attorney at law Dr. Rainer Buchert from the law firm Buchert Jacob Partner in Frankfurt am Main.
Contacts:
Buchert Jacob Partner
Kaiserstraße 22
60311 Frankfurt am Main
Germany
Phone: +49 69 710 33 330 (Office) or directcontact +49 6105 921 355
E-Mail: kanzlei@dr-buchert.de
Dr. Buchert can be reached by phone on weekdays from 8 a.m. to 8 p.m., but in principle also beyond that. He is available for personal discussions upon making an appointment.
Dr. Buchert is subject to the legal duty of confidentiality and accepts information and hints confidentially in German and English. He reports to the Central Compliance Function or the Human Rights Officer of KAP AG only with the express consent of a whistleblower. The identity of a whistleblower is generally not disclosed unless the whistleblower requests this or expressly agrees to this.
You can also send Dr. Buchert a confidential electronic message via an SSL-encrypted contact form. The link
leads to a reporting template, that is available in several languages.
It should be emphasized that the ombudsman can also be contacted if a whistleblower is initially seeking advice in connection with misconduct that has been observed.
Dr. Rainer Buchert will be represented by his colleague attorney at law Dr. Caroline Jacob from the same firm in case of his unavailability.
The use of ombudspersons does not involve any costs for whistleblowers.
All compliance hints and complaints received by KAP Group is taken seriously and processed in strict confidentiality by the Central Compliance Function at KAP AG. Whistleblowers receive feedback from the ombudsman, within the scope of the legal possibilities, with a result of tips having been investigated and what has been done on the basis of their tips.
Enclosed you will find the link to the Complaints Procedure for The Supply Chain Due Diligence Act at KAP AG.
The Whistleblower Protection Act stipulates that in cases in which the company can take effective action against a violation, reporting to an internal reporting office should be preferred (Section 7, Para. 1, Sentence 2 of the Whistleblower Protection Act). Regardless of this, you also have the option of contacting external reporting offices with information (Section 7, Para. 1 of the Whistleblower Protection Act). You can find information about the currently existing external reporting offices (Germany and EU) via the link External Reporting Offices at National Level (§§ 19 - 23 HinSchG).