Compliance

The goal of Witzenmann's compliance management is to ensure adherence to the legal provisions applicable to the Witzenmann Group worldwide, the company's internal guidelines, and fundamental ethical principles and international standards.

The CMS covers the entire Witzenmann Group. It is aligned with Witzenmann's business activities and requirements and primarily targets the areas that were identified as relevant for Witzenmann in the risk analyses. Particular focal points of compliance work at Witzenmann are human rights and environmental protection, data protection, product conformity, antitrust law, prevention of corruption, prevention of money laundering, and export control and sanctions requirements.

Lawful, ethical conduct with integrity is the basis of Witzenmann's business activities. This is laid down in the Witzenmann Code of Conduct.

The management and executives of Witzenmann are fully committed to this and live it out to their employees ("Tone from the Top/Middle").

Employees have the opportunity at any time to contact their supervisors, the management or the compliance officer with compliance questions and with information about risks or irregularities. A whistleblower system is also available to all employees, in which the informants are subject to special protection.

Compliance is the management task of all executives in the company. Organizational measures, in particular the provision of suitable and transparent processes as well as the provision of the necessary resources, ensure that the CMS unfolds within the entire Witzenmann Group.

Responsibility for the CMS lies with the Legal and Compliance department of Witzenmann GmbH, which reports regularly and, if necessary, immediately directly to the responsible Managing Director. The Legal and Compliance department develops the Group-wide standards for compliance management and advises the divisions as the first point of contact for all compliance issues.

The Legal and Compliance department is supported by the global compliance network of the Witzenmann Group. There is a local compliance contact for each of the international subsidiaries. He or she supports the management in adhering to rules and implementing compliance management on site, particularly with regard to the implementation of group-wide standards and compliance with the applicable local law.

Compliance risk analyses form the basis for the management of compliance risks at Witzenmann. Within the scope of regular compliance risk analyses, the organization is systematically examined for compliance risks. The identified risks are recorded, analyzed, and evaluated.

If special circumstances require it, the regular compliance risk analysis is supplemented by event-related audits and risk assessments.

Based on the identified compliance risks, Witzenmann develops and implements principles and measures to reduce the risk of compliance violations. These include:

• the Witzenmann Code of Conduct for Employees,
• the Witzenmann Code of Conduct for Suppliers,
• topic-specific guidelines and guidance documents,
• Process, work and organizational instructions,
• the business partner check,
• Trainings, e-learning programs and workshops,
• the confidential and, if desired, anonymous whistleblower system,
• the range of consulting services on compliance issues.

Witzenmann informs employees and business partners about the compliance standards that apply at Witzenmann in various ways, including internal communications from the Executive Board and the Legal and Compliance Department, in personal discussions, when responding to customer inquiries, and through publications on the intranet and the Internet.

Witzenmann employees are trained at regular intervals on the compliance topics relevant to them. They are taught how to behave with integrity and in compliance with the rules in everyday business. The needs-oriented training program includes both classroom training and e-learning.

As part of regular risk analyses, compliance content is explained in personal discussions with function holders from all relevant areas of the company. The function holders can name compliance risks from their areas and ask compliance experts.

All employees and executive bodies of Witzenmann also have the opportunity to obtain sound advice on compliance issues from the Legal and Compliance department at any time. If necessary, specialized legal advisors are consulted.

Witzenmann continuously reviews the CMS for its effectiveness and appropriateness as well as for any need for change. If new legal requirements arise, risks change, or new risks are added, the system is adapted to the new circumstances. To this end, catalogs of measures and processes are developed and subsequently implemented.

Findings from the results of compliance risk analyses, audits, suggestions from employees and managers and, where appropriate, information from the whistleblower system are used to continuously develop and improve the system.