Frequently Asked Questions about the Clinton Group Whistleblower Office

What is the whistleblowing centre?

The Whistleblower Office is an internally established and operated central office for companies of Clinton Großhandels-GmbH and all companies in which Clinton Großhandels-GmbH holds a direct or indirect interest and/or which constitute an affiliated company pursuant to §§ 15 et seq. AktG (hereinafter collectively referred to as the "Clinton Group")

It is used by whistleblowers who have obtained information about offences and wish to draw attention to them.

Who can use the whistleblowing centre (personal scope of application)?

Natural internal and external persons - employees, former employees or applicants, contractors, suppliers or other third parties who have obtained information about violations by the Clinton Group in a professional context - can contact the Whistleblower Office.

Which offences can be reported (material scope)?

Offences are acts or omissions in the context of a professional, entrepreneurial or official activity that are unlawful or abusive and contravene legal provisions of the applicable laws and regulations of Union law and the respective national law, which fall within the respective national scope of application of the Whistleblower Protection Act (Germany: § 2 HinSchG, Austria: § 3 HSchG). The information must concern criminal offences or offences subject to fines. This includes, for example, the following offences:

• Financial services, financial products and financial markets as well as the prevention of money laundering and terrorist financing,
• Product safety and conformity,
• Road safety,
• Environmental protection,
• public health,
• Consumer protection,
• Protection of privacy and personal data as well as security of network and information systems;

What is the whistleblowing centre not responsible for?

A distinction must be made between whistleblowers and consumers who wish to submit a complaint to the whistleblowing centre or make an enquiry. These people are usually customers who have a personal concern in connection with a purchase. For these concerns, the contact address kontakt@campdavid-soccx.de set up.

The whistleblowing office is also not responsible for labour law conflicts such as bullying, non-contractual employment, incorrect remuneration, unequal treatment - as long as these do not fall under the General Equal Treatment Act.

The whistleblowing centre is also not responsible for reports of private misconduct.

How and where can you submit a tip?

If you have concrete, well-founded indications of serious legal violations or breaches of the rules, reports can be submitted to the whistleblowing centre or contact can be made for a personal discussion:

Supervisor/superior:
Potential misconduct can traditionally be reported to the responsible line manager. Whistleblowers can approach the line manager in person or put the matter in writing. If you wish, a personal meeting can also take place. It may be possible to find a solution quickly and effectively.

by e-mail:
hinweis@clinton.de

by letter post:
Clinton Großhandels-GmbH
Whistleblowing centre
P.O. Box 80, D-15366 Hoppegarten
Labelling with "Confidential" is recommended.

Are anonymous tips followed up?

In general, the following should be taken into account for anonymous reports: When processing reports, queries are often necessary in order to fully understand and assess the information. This important communication is not possible for anonymous reports without the whistleblower's contact details. In the worst case scenario, this can mean that reports that need to be followed up cannot be processed due to a lack of information. It is therefore important, but not mandatory, to provide contact details.

How should the notification be made?

In order for a report to be processed and investigated correctly, it is important that it is as specific as possible. Information on the following questions will help:

• Which Clinton Group company is affected by the incident?
• What misconduct did you perceive with details of accused and/or affected persons and witnesses?
• When and where did the incident take place?
• Have you already reported the incident elsewhere?
• Is the incident still ongoing?

Provide us with suitable evidence to process the tip.
Sensitive information such as racial or ethnic origin, political opinions, religious or philosophical beliefs and data on health or sex life that is not relevant to the incident should be avoided.

What happens after a report?

The Whistleblowing Unit team follows up every single tip-off. The report is documented and information is secured. This serves as evidence for follow-up measures.

While strictly maintaining confidentiality, the whistleblowing centre examines the validity of the report, initiates internal investigations to clarify the facts and takes appropriate follow-up measures. These include, for example, the introduction of appropriate preventive measures for comparable future cases or the decision not to follow up on the report due to a lack of substance. A report is not followed up if, for example, insufficient information is available for an adequate investigation and there is no possibility of obtaining further information or the report is proven to be a false report.

You will receive confirmation of receipt within seven days and feedback on the action taken on your report within three months.

How is confidentiality maintained?

The whistleblowing office is designed in such a way that only those responsible for receiving and processing the reports and those involved in the fulfilment of these tasks have access to the incoming reports. The technical design of the specific reporting channel ensures that no unauthorised persons have access to the identity of the whistleblower, the persons who are the subject of the report or other persons named in the report.

The identity of the whistleblower who reports serious wrongdoing or irregularities in good faith will be kept strictly confidential. Apart from certain exceptional cases where the whistleblower consents to such disclosure, where this is necessary for subsequent criminal proceedings or where the whistleblower makes a false statement with malicious intent, the identity of the whistleblower will never be disclosed. The identity of a whistleblower who intentionally or through gross negligence reports incorrect information about violations is not protected. In this case, this personal data may be disclosed to the judicial authorities.

What do I have to fear from a report?

We follow up all reports of violations through internal investigations. If you, as a whistleblower, report legal violations or violations of internal regulations or attempts to conceal such violations, you will be protected. You therefore do not have to expect any disadvantages, provided that you have submitted your information on the basis of concrete evidence and you are convinced to the best of your knowledge and belief that the information you have passed on is correct.

However, the contact details of the whistleblowing centre may not be used to make false accusations or intentionally report false information. The whistleblower is obliged to compensate for any damage resulting from the intentional or grossly negligent reporting or disclosure of incorrect information.

External reporting centres?

The use of the internal whistleblowing centre is not mandatory. You are free to choose whether to contact our internal whistleblowing centre or an external reporting office:

GermanyThe federal and state governments will set up and operate external reporting centres at various authorities. The Whistleblower Protection Act (HinSchG) determines the authorities at which the federal government must set up and operate external reporting offices. On the website of the Federal Office of Justice the reporting channels through which whistleblowers can contact external federal reporting centres are published.

Austria: On the basis of the HSchG Federal Bureau of Anti-Corruption (BAK)
an external reporting office pursuant to § 15 HSchG set up.