In accordance with the Whistleblower Protection Act and its internal Code of Conduct, German Sparkassenstiftung for International Cooperation (DSIK) has set up an internal reporting office. The aim of this office is to ensure that employees and external persons who become aware of an offence committed by DSIK or its employees can report it without fear of reprisals (e.g. dismissal, warning, negative assessment). In addition, all reports, including the personal data of the whistleblower and persons named in the report, are treated in strict confidence.

The Whistleblower Protection Act protects employees or former employees who report:

• Offences that are punishable by law, e.g. corruption, tax evasion
• Offences that are subject to fines, e.g. Minimum Wage Act, Temporary Employment Act
• Offences that violate specifically named national or European law, e.g. money laundering, environmental law

In addition, the management assures that reports by employees, former employees, partners and external persons on violations against the Code of Conduct of German Sparkassenstiftung will be investigated. These reports shall and will also not lead to reprisals.

False reports made intentionally or through gross negligence can be charged to the whistleblower in both cases. In addition, the requirement of confidentiality no longer applies and a claim for damages may arise.

As the Whistleblowing Protection Act and DSIK's Code of Conduct are legally two separate subject areas, reporting and processing are also carried out separately. The reporting app therefore asks, whether a violation of the Code of Conduct or a report under the Whistleblower Protection Act will be submitted. The reporting office is staffed by trained personnel. Additionally, a confidential committee can be involved in the event of reports of violations against the Code of Conduct.

The procedure after submitting a report is as follows:

1. Successfully submitted reports receive a confirmation of receipt.
2. All reports are checked for their validity. It is reviewed whether the report falls under the Whistleblower Protection Act.
3. If necessary, the whistleblower is contacted for further information.
4. Appropriate follow-up measures are taken (e.g. consultation with the committee, internal investigation, management informed if necessary, referral to the authorities) or, if the report is not valid, the investigation is discontinued.
5. The whistleblower is informed about the follow-up measures taken by DSIK.

To the DSIK complaints and internal reporting office: ENGLISH VERSION