Whistleblower Protection Act
Information on whistleblower protection
1. Preface
Compliance with the law, internal guidelines and the principles of our Code of Conduct is a top priority for the Sebapharma Group. It is of crucial importance for us to learn of possible misconduct and to ensure that it is clarified accordingly.
The companies of the Sebapharma Group listed below are subject to the provisions of the HinSchG:
- Sebapharma GmbH & Co. KG
- Maurer Pharma Nord GmbH
The established whistleblowing procedure guarantees the most comprehensive protection for both the whistleblower and the person(s) concerned. This also includes the fact that we offer the possibility of anonymous contact and reporting.
An investigation is only initiated after a careful examination of the information and the existence of concrete evidence of a serious breach of the rules. This is carried out in strict confidentiality and as part of a fair, swift and confidential process.
2. Contact internal reporting office
Reports can be made to our external whistleblower officer, Lena Ludwig or her representatives, either by email to hinweise-sebamed@psw.de or by telephone on +49 159 046 130 67.
We provide encryption for reports by email. See section 8.
The anonymity of the whistleblower will be preserved vis-à-vis the Sebapharma Group and will only be disclosed with prior express consent.
3. Reports of violations that guarantee whistleblower protection
Subsequent legal violations can be reported via our internal reporting centre:
- Tax fraud
- Money laundering
- Inconsistencies in the awarding of public contracts
- Errors in product and traffic safety
- Offences against environmental protection
- Risks to public health
- Consumer and data protection offences
- Offences against criminal law
- Violations that constitute an administrative offence and are contrary to the purpose of the standard, specifically the protection of life, limb or health, as well as the protection of the rights of employees
4. Content of a message
The more information, evidence and proof you can provide us with, the better your report can be processed. You can use the following information as a guide:
- Which company/location is it?
- Your name and position or what is your connection to the company?
- What would you like to report?
- When was this incident?
- Who is involved in the incident? (persons, department, etc.)
- Are there any other witnesses?
- If you have any supporting documents or evidence, e.g. documents, photographs, etc., you can provide these with your report.
- Finally, if you wish, please let us know how the whistleblower officer can contact you to ask questions and inform you of the outcome of the investigation?
5. Abuse of the reporting office
The Sebapharma Group reserves the right to file a criminal complaint or take other appropriate sanctions in the event of knowingly false reports and wilful misuse.
6. External reporting centres
External reporting centres are also available to you at the respective monitoring authorities. For contact information, please visit the websites of the relevant authorities.
7. Course of a procedure
Upon receipt of the report, the whistleblower will receive a confirmation of receipt from the whistleblower officer within 7 days. Unless there is no means of contact or the report was made anonymously.
After 3 months, the whistleblower will be informed of any follow-up measures planned or already taken. These must be proper follow-up measures in accordance with §18 HinSchG. These may include internal investigations or possible measures to rectify the problem.
If no sufficient evidence is found despite investigations, the whistleblower will be informed that the procedure has been closed due to a lack of evidence. In such a case, the whistleblower is free to contact the external complaints office. This reporting centre has 6 months to conclude the proceedings.
8. Safety of processing
Appropriate protective measures have been taken for the implementation of the procedure, both of a technical and organisational nature.
To enable you to send a secure message, we provide you with the public keys for encrypted e-mail communication below.
9. Changes
Please note the current status of this page, as we regularly make changes to the content as part of our review processes.
Status: November 2023