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re. whistleblower system

A whistleblower system is used to report violations of the rules and is an important tool for the ep group to ensure corporate due diligence, as the second pillar of the United Nations Guiding Principles for Business and Human Rights.
We can only avoid damage to our company, our employees and our business partners if rules and standards are observed. Compliance with laws, specifications and guidelines as well as internal regulations is very important to the ep group. Misconduct must therefore be detected at an early stage.
In order to investigate serious violations fairly and appropriately, we have created an opportunity to address misconduct here. It enables employees and external whistleblowers to report information, violations and complaints worldwide.
Violations that pose a high risk include, for example, corruption offences, violations of anti-trust law and money laundering regulations, but also violations of binding technical regulations or violations in connection with environmental regulations or human rights.
The ep group encourages all persons inside and outside the company who observe or suspect violations in connection with the company for specific reasons to contact the Compliance department without fear of reprisals and to express the information openly.
Whistleblowers who report possible violations based on concrete evidence are protected by the company. The confidentiality of such information is guaranteed. Discrimination or intimidation of an employee for reporting a violation is itself a violation and may result in disciplinary action under labour law. Whistleblowers should disclose their identities so that they can be asked questions that could aid the investigation. If a whistleblower requests that their identity not be disclosed to other parties within the company, this request will be honoured. Anonymous reporting is also possible at any time using our report form.
The ep group would thus like to ensure a fair and transparent procedure that takes into account both the principle of proportionality for the person concerned and the protection of the whistleblower.
Information about possible violations is treated transparently and always confidentially by the Compliance department as part of the procedure described below:

  1. Reporting violations and contacting the Compliance department
    If you have specific information about violations and complaints in connection with the ep group's business activities, you can contact the Compliance department via the following channels:
    engineering people GmbH
    Compliance Department -personal/confidential-
    Söflinger Straße 70
    89077 Ulm
    You can also use the reporting form below at any time to report information, violations and complaints - also anonymously - to the Compliance department.
  2. Case recording
    After receiving the report, the Compliance department carries out an initial risk-based assessment of the possible violation. The violations that are classified as high risk for the company include, among others, corruption offences, violations of antitrust law, violations of money laundering regulations as well as human rights violations. If there is information that poses a high risk for the company, its employees or business partners, the incident will first be legally examined. If the examination shows that the suspicion is confirmed, appropriate measures will be taken. For example, the case can be assigned to the responsible departments (e.g. Human Resources, IT, Accounting or Controlling) with specific orders for action.
    All other information will be forwarded by the Compliance department to the other departments. The whistleblower will be informed in advance of the forwarding. The violations include, for example, theft, embezzlement or personal enrichment with a value of less than €100,000.00 insofar as they are not related to corruption.
    The Compliance department accompanies the processing of information until the case is concluded. The Compliance department ensures the highest level of confidentiality.
  3.  Investigation
    In cases with a high risk for the company, its employees or business partners, appropriate follow-up measures (e.g. an investigation order) are taken. Other cases are investigated by the relevant department.
    In the event of an investigation, the person potentially affected will be informed immediately in writing of the suspicion, as far as this is possible for reasons related to the investigation, and will be given the opportunity - as quickly as possible - to comment on the allegations. If required, potentially affected ep group employees can consult a person they trust (e.g. a lawyer) and inform their superiors of the allegations.
    As long as a violation is not proven, the presumption of innocence applies. Incriminating and exculpatory facts are equally taken into account in the investigation.
    In addition, our whistleblower system attaches great importance to fairness - both in communicating with whistleblowers and with employees or business partners who are affected by an allegation. The Compliance department always applies the principle of proportionality and examines which consequences are suitable, necessary and appropriate in each individual case.
  4. Conclusion of the case
    The person to whom the allegation relates and, if applicable, their supervisor will be informed of the conclusion of the case. The result of the investigation will be communicated to the person concerned in writing. Unless the whistleblower remains anonymous, the whistleblower will also be informed of the conclusion of the case and the final outcome.
    If the allegations prove to be untrue, the person concerned will be exonerated.
    If the suspicion against an ep group employee is confirmed, the case will be forwarded to the Personnel Department for any necessary labour law measures. If necessary, the person concerned will be interviewed again, as will their manager. Personnel measures are taken in accordance with the principle of proportionality. In the event of misconduct by a business partner, appropriate consequences will also be drawn in accordance with the principle of proportionality. If a business partner refuses to implement a jointly developed improvement plan or if the business partner does not improve, the ep group can temporarily suspend or terminate the business relationship after appropriate notice and warning.
    In order to assess what measures are appropriate in response to a breach, the principle of proportionality applies, inter alia: the following criteria are regularly taken into account:
    -    Nature and severity of the violation
    -    Responsibility of the person concerned (intent, negligence)
    -    Extent, possibility of reversal and probability of damage occurring
    -    Attitude of the person concerned regarding the violation
    -    Participation in clarifying the facts and/or compensation for the damage caused and/or a possible self-disclosure by the person concerned
    -    Influence of the ep group on the business partner
    Specific measures in the event of violations against ep group employees are based on local law but, depending on the severity of the violation, can include both disciplinary and labour law measures (e.g. admonition, warning, ordinary or extraordinary termination, reduction of variable remuneration components, recovery, repayment and/or compensation claims). If criminal violations are discovered, the ep group reserves the right to file criminal charges.
    Measures against business partners are also carried out in accordance with local law and the corresponding contractual agreements between the ep group and the business partner.
    All data are deleted after appropriate retention periods.
  5. Report and opportunities for improvement
    We use various communication measures to continually increase trust in the whistleblower system and increase awareness of the whistleblower system among employees. The Compliance department thus provides information on the whistleblower system as part of the onboarding of new employees. Training courses on the whistleblower system are offered at regular intervals. In addition, the Compliance department regularly and appropriately informs employees about the number of reported violations and the type of confirmed violations. For business partners, the ep group explicitly refers to the whistleblower system in its supplier obligations for contractors/suppliers.
    The Compliance department regularly reports to management on newly opened and closed cases. By processing reported incidents, the whistleblower system contributes to the continuous development of the ep group's compliance processes and guidelines.

In addition to the company's own whistleblower system, the ep group participates in the implementation of the requirements and guidelines of the "National Action Plan for Business and Human Rights of the Federal Republic of Germany".
Whistleblowers and other third parties have the right to sue in national courts. In particular, submitting a notice of violations does not constitute a waiver of an existing right to file a lawsuit. In addition, the ep group always maintains confidentiality as part of its investigations and no separate confidentiality agreements are concluded. If necessary, the ep group will cooperate with state law enforcement authorities.
Please direct your questions and suggestions regarding the ep group whistleblower system to the Compliance department:
engineering people GmbH
Compliance Department -personal/confidential-
Söflinger Straße 70
89077 Ulm
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