Whistleblowing hotline / reporting offices for whistleblowers
Whistleblowing hotline / reporting offices for whistleblowers
Our promise to act professionally and in accordance with applicable laws and ethical values with each other and with our clients requires integrity in our words and actions. We are clearly committed to the values set by KPMG Law, in the form of a Code of Conduct. Questioning applicable laws or our values is unacceptable. To maintain our culture of integrity, KPMG Law maintains a whistleblowing hotline in Germany.
Which reporting offices does KPMG Law maintain?
In compliance with the legal requirements of the Act for the Better Protection of Persons Providing Information (Whistleblower Protection Act, “HinSchG”), KPMG Law maintains the reporting channels for whistleblowers described in more detail below. The so-called “Whistleblowing Hotline” is designed as an internal reporting office within the meaning of § 14 HinSchG.
Who can use the Whistleblowing Hotline?
The whistleblowing hotline can be called by all employees within the meaning of § 3 para. 8 HinSchG, but also by clients, subcontractors, suppliers and other third parties.
With what information can one contact the Whistleblowing Hotline?
The Whistleblowing Hotline allows reporting of illegal or unethical actions when other communication channels have proven to be less effective or inappropriate. In such cases where effective internal action can be taken against a violation and whistleblowers do not have to fear reprisals, reporting to the Whistleblowing Hotline as an internal reporting point should be preferred.
The Whistleblowing Hotline can be used in particular for reporting and disclosing information about violations as defined in § 2 HinSchG. This includes violations that are punishable by law or – insofar as the violated regulation serves to protect life, limb or health, to protect the rights of employees or their representative bodies – are subject to fines, or other violations of legal provisions, e.g., the German Corporate Governance Code. on combating money laundering and terrorist financing, on the protection of personal data, on the audit of financial statements of public interest entities, or on the financial reporting of publicly traded companies.
The Whistleblowing Hotline can also be used to report misconduct by KPMG Law employees with regard to professional standards or against self-imposed values in the form of the Code of Conduct.
We encourage anyone to raise a concern if it affects KPMG Law in Germany or its employees or management.
How to submit a report?
KPMG Law operates the whistleblowing hotline as an internal reporting office with the involvement of an external lawyer based in Berlin. The involvement of a person outside the organization who is professionally bound to maintain confidentiality ensures confidentiality for all who file a report, anonymity for those who do not wish to disclose their name, and impartial action because he or she is independent and not bound by instructions. The Whistleblowing Hotline offers the following ways to make a report:
- By phone using the telephone number: +49 30 31 01 82 15
You can reach attorney Dr. Margarete Gräfin von Galen at the following telephone number. She is available during regular office hours (9 a.m. to 6 p.m.). Outside these office hours, an answering machine is available to take messages.
- By mail or e-mail to the following contact information:
Dr. Margarete Countess von Galen, Attorney at Law
- Use of a web-based online reporting system *
From here, the report is made available to Dr. Margarete Gräfin von Galen, attorney at law, and – unless notification is excluded by the person making the report – to a narrow circle of employees in Quality & Risk Management at KPMG AG Wirtschaftsprüfungsgesellschaft, which acts on behalf of KPMG Law in this respect.
What happens to a message?
Each report is processed in accordance with the legal requirements (in particular § 17 HinSchG ).
The internal reporting office receives each report, confirms receipt, evaluates it, discusses the facts with the whistleblower and decides on the next reported steps for clarification and investigation depending on the violations and/or conspicuous features discussed. This is done in consultation between attorney Dr. Margarete Gräfin von Galen and the employees from the Quality & Risk Management department appointed in accordance with § 15 HinSchG. The internal reporting office determines the follow-up measures in terms of § 18 HinSchG.
Dr. Margarete Gräfin von Galen, attorney-at-law, maintains contact with the whistleblower and communicates the information about the conclusion of the investigation and the result found to him.
The content of any report and any reporting person within the scope of the Whistleblower Protection Act shall be subject to the protection of this Act. Reports are treated as strictly confidential; upon request, the anonymity of a whistleblower will be preserved by attorney Dr. Margarete Gräfin von Galen, also vis-à-vis KPMG employees in the internal reporting office.
Reports not submitted by KPMG Law in Germany and e.g. concern another KPMG firm that is a member of the global KPMG organization of independent member firms are referred to KPMG International. If a report is forwarded in this manner, it will be subject to the appropriate confidentiality and anti-retaliation rules.
KPMG Law encourages reporting of violations of laws and ethical principles. Whistleblowers and, in particular, employees need not fear any negative consequences because of a report they have made or supported in good faith within the meaning of Sections 33 and 34 HinSchG. KPMG Law’s Code of Conduct prohibits sanctions against anyone who, in good faith, reports a possible violation or participates in an investigation, even if there is insufficient evidence to substantiate the concerns raised.
* KPMG Law partners with Clear View Strategic Partners** in Canada, an independent provider of web-based hotline services. Please note the instructions in the reporting system, especially with regard to the options for preserving anonymity.
** Clear View ConnectsTM is a registered trademark of ClearView Strategic Partners Inc.