Ratio­na­le

The manage­ment of Noven­tiz GmbH, Noven­tiz Dual GmbH, Noven­tiz Digi­tal GmbH,
Noven­tiz Sel­ect GmbH, Noven­tiz GEE GmbH and Reco­no­my Deutsch­land GmbH, her­ein­af­ter refer­red to coll­ec­tively as Noven­tiz, is awa­re that a par­ti­cu­lar­ly pro­duc­ti­ve envi­ron­ment can only be estab­lished through free and open inter­ac­tion, both within Noven­tiz and with its cli­ents and sup­pli­ers.
In order to achie­ve, main­tain and pro­mo­te this, open and honest com­mu­ni­ca­ti­on is essen­ti­al, so as to ensu­re that any poten­ti­al mis­con­duct can be dis­c­lo­sed and reme­di­ed.
The­se gui­de­lines are inten­ded to pro­vi­de a means of redress if such mis­con­duct can­not be reme­di­ed through “nor­mal” manage­ment pro­ces­ses.

Objec­ti­ve

The objec­ti­ve of the­se gui­de­lines is to encou­ra­ge anyo­ne working for or with Noven­tiz to report inci­dents of suspec­ted cor­po­ra­te mis­con­duct wit­hout pla­cing them­sel­ves or their busi­ness rela­ti­onship with Noven­tiz at risk.

The­se gui­de­lines app­ly in cases whe­re a per­son belie­ves firm­ly and in good faith that cor­po­ra­te mis­con­duct has occur­red, is occur­ring or may occur. This may include, but is not limi­t­ed to, the fol­lo­wing:

  • a cri­mi­nal offence, for exam­p­le fraud
  • the dan­ger to the health and safe­ty of any per­son
  • end­an­ger­ment of, or actu­al dama­ge to, the envi­ron­ment
  • a mis­car­ria­ge of jus­ti­ce
  • con­tra­ven­ti­on of the law by the com­pa­ny
  • the belief that someone is cove­ring up wrong­do­ing
  • sus­pi­ci­on of modern slavery

Pro­ce­du­re

In the first ins­tance, you should dis­cuss any con­cerns with your line mana­ger or the line mana­ger of the per­son about whom you have con­cerns. If the issue rela­tes to your line mana­ger, you should dis­cuss the mat­ter with a mem­ber of the manage­ment team and/or, if you feel it is appro­pria­te, with the head of depart­ment.

If you do not wish to take this rou­te, you may also cont­act the Whist­le­b­lo­wing Offi­cer by e‑mail at whistleblowing@noventiz.de or by tele­pho­ne on +49 221 800 158 660.

Your com­plaint will be inves­ti­ga­ted imme­dia­te­ly. You will recei­ve con­fir­ma­ti­on that we have recei­ved your com­plaint within seven days, pro­vi­ded we have your cont­act details. You will be infor­med of the results of the inves­ti­ga­ti­on and any mea­su­res taken no later than three months after your com­plaint has been recei­ved.

Noven­tiz is com­mit­ted to con­duc­ting its busi­ness fair­ly, jus­t­ly and within the con­fi­nes of the law, and thus expects tho­se who work for or with Noven­tiz to share this com­mit­ment. Noven­tiz is also awa­re that dis­clo­sing such infor­ma­ti­on may be dif­fi­cult, as it may initi­al­ly imply that a col­le­ague or busi­ness part­ner has beha­ved in a repre­hen­si­ble man­ner, which may lead to repri­sal. If you have the impres­si­on that your com­plaint could have nega­ti­ve con­se­quen­ces for you, or that the feed­back you recei­ved was not satis­fac­to­ry, plea­se cont­act the Noven­tiz manage­ment by e‑mail and descri­be the cir­cum­s­tances from your point of view.

Assu­rance

Anyo­ne who reports a poten­ti­al grie­van­ce is pro­tec­ted from any nega­ti­ve con­se­quen­ces of doing so – be this under labour law or as part of con­trac­tu­al coope­ra­ti­on – even if their com­plaint is sub­se­quent­ly pro­ven to be unfoun­ded. The pre­re­qui­si­te for this is that the indi­vi­du­al made the report in good faith and they ente­red the com­plaint belie­ving that the alle­ga­ti­ons they were making were true.

Sta­tus: 06/2023