Whistleblowing System

Raise concerns securely and confidentially

Acting lawfully, responsibly and with integrity is an essential part of the way we work at ROBIN. If you become aware of potential misconduct or a breach of the law in connection with ROBIN, you can report your concerns through our internal reporting channel.

Reports are received and handled by an independent external contact point. All information will be treated carefully and confidentially.

What can be reported?

The reporting channel can be used to report suspected misconduct or breaches, including:

• breaches of laws, regulations or internal policies
• bribery, corruption, fraud, theft or misappropriation
• breaches of health and safety or employment regulations
• discrimination, harassment or other serious misconduct
• environmental or human rights violations
• attempts to conceal unlawful conduct
• other conduct that could cause serious harm to ROBIN, its employees or third parties

Please only report information if you have reasonable grounds to believe that it is true.

Who can make a report?

The reporting channel is available to anyone who obtains information about potential misconduct in a work-related context. This includes, in particular:

• current and former employees
• job applicants and trainees
• temporary workers and contractors
• suppliers, service providers and business partners
• other individuals with a professional connection to ROBIN

How to submit a report

ROBIN has appointed Hackling Menzel StrukturPartner GmbH as an independent contact point to receive and handle reports through its internal reporting channel.

Hackling Menzel StrukturPartner GmbH 
Poststr. 18
49808 Lingen (Ems)
Germany

Contact: Tobias Hackling 
Email: info@hmsp.gmbh 
Telephone: +49 (0)591 9778461-0

Reports may be submitted by email, telephone or post. At your request, a personal meeting can also be arranged within a reasonable period of time.

Please describe the matter as precisely as possible. The following information may help with the assessment:

• what happened
• when and where it happened
• which individuals or organisations were involved
• whether the matter is ongoing
• whether supporting documents or other evidence are available

Please do not put yourself or anyone else at risk in order to obtain further information.

Confidentiality and protection against retaliation

Reports will be treated confidentially. The identities of the person making the report, the person concerned by the report and any other individuals named in it will be protected in accordance with the applicable legal requirements.

Information will only be accessible to the persons authorised to receive and process reports. An identity may only be disclosed where this is required or permitted by law.

Individuals who make a report and have reasonable grounds to believe that the information reported is true are protected against retaliation to the extent provided by applicable law. Threats and attempted retaliation are also prohibited.

What happens after a report has been submitted?

Provided that you have supplied contact details, you will normally receive acknowledgement of your report within seven days.

The reporting office will then:

1. examine whether the report falls within the scope of the applicable whistleblower protection legislation;
2. assess the information and its plausibility;
3. contact you if further information is required;
4. initiate or recommend appropriate follow-up measures; and
5. provide feedback within three months of acknowledging receipt of the report.

Feedback can only be provided to the extent that it does not affect internal investigations or the rights of the individuals concerned.

Reports from outside Germany

ROBIN’s internal reporting channel is available irrespective of where you are based.

The reporting channel is operated for a German company and in accordance with German law. If you work or reside outside Germany, or if your report concerns events in another country, the laws of that country may also apply. These laws may provide different rules concerning:

• who qualifies for whistleblower protection
• which types of concerns are protected
• confidentiality and anonymous reporting
• protection against retaliation
• the authorities to which an external report may be made
• deadlines and available legal remedies

Within the European Union, national legislation implementing Directive (EU) 2019/1937 may differ from one Member State to another. The United Kingdom and other countries outside the European Union have their own whistleblowing regimes.

The legal protection available does not depend solely on your nationality or place of residence. Your employment relationship, place of work, the organisation concerned, the location of the reported conduct and the reporting channel used may also be relevant.

Using ROBIN’s internal reporting channel does not restrict any right you may have to report a concern to a competent external authority. If you are uncertain about your legal position, you should consider obtaining independent legal advice.

External reporting

You may also submit a report to a competent external reporting authority.

In Germany, reports may be made to the Federal External Reporting Office at the Federal Office of Justice. Depending on the subject matter, another specialised authority may be responsible.

If your report has a connection with another country, you may also be entitled to contact the competent reporting authority in that country.

Data protection

Personal data submitted through the reporting channel will only be processed where this is necessary to receive, assess and handle the report, communicate with the person making the report and take appropriate follow-up measures.

Data Protection Officer: Jens Anneken

Further information about the processing of personal data can be found in our Privacy Policy.