It is a matter of course for our company that we offer a whistleblower protection system in which you can report information personally or anonymously. This system is implemented by setting up a reporting office and this reporting channel, which are operated by an external service provider.
Note: as of December 17, 2023, companies of our size areconv obliged to implement the Whistleblower Protection Act (HinSchG) and the EU Whistleblower Directive.
We are convinced of the idea of the directive and even go beyond legal requirements by not only setting up an internal reporting office for our employees, but also extending this offer to our customers and service providers.
In principle, it is possible to report violations within the meaning of the Whistleblower Protection Act, which may relate to the following topics, for example:
1. Money laundering
2. Privacy
3. Environmental protection
4. Embezzlement
5. Conflicts of interest
6. Manipulation of business documents / balance sheets
7. Antitrust and competition law
8. Violations of codes of conduct at the workplace as well as human rights violations.
The plausibility and relevance of each report will be checked by our independent external service provider upon receipt. Confidentiality and anonymity are guaranteed at all times, provided that you submit your report anonymously. You can select this option when submitting your report.
The following confidentiality conditions apply:
What our whistleblower system offers
- No information identifying the whistleblower is given to the contact persons at Comma Soft.
- Each report is formally adapted to make it even more anonymous. This means that double punctuation is removed and all words are written in lower case.
- All information is encrypted end-to-end so that sensitive information is secured.
What whistleblowers can do beyond to make themselves anonymous
- Send reports from outside the company network (Internet / VPN), this prevents entries in our company logs.
- Use a device (smartphone, computer, etc.) that has not been provided by Comma Soft; this prevents the reporting device from being identified.
- We recommend avoiding phrases or abbreviations that are otherwise frequently used in conversations or emails.
Irrespective of this official reporting system, please note that we maintain an open and trusting corporate culture at Comma Soft and that you are welcome to approach the known contact persons personally at any time, if you wish to discuss issues that matter to you.