Compliance: speak up

Why should I submit a report?

Your report is important to help protect the IMP and its employees from the negative consequences of non-compliance and inappropriate behaviour.

If potential non-compliance or inappropriate behaviour is immediately brought to the attention of responsible IMP staff, it enables them to take action and deal with issues timely and appropriately. It will also support the IMP in addressing any future risks resulting from non-compliance and inappropriate behaviour, and therefore finally helps prevent financial or reputational damage to the IMP.

Your report should be well-founded, to the best of your knowledge correct and complete, made in good faith, and supported by any evidence on the incident you are in possession of.

False and unfounded allegations will not be tolerated and might lead to legal and disciplinary consequences.

What sort of incidents can be reported?

There are defined categories of incidents which can be reported and which will be explained when you continue to submit a report. Please limit your report to one of those categories.

If an incident is related to something which is not included in one of those categories, IMP employees are kindly requested to directly contact the responsible department or Human Resources.

Can I report anonymously?

Yes, you can report anonymously. The BKMS^® System places utmost importance on protecting whistleblowers and enables you – while keeping your anonymity – to communicate with relevant persons at the IMP also in subsequent steps of processing the initial report.

However, reports that are not anonymous are generally considered more reliable and make it easier to follow up on the reported allegations.

Any employee who threatens, retaliates against, or harasses any person who has reported a compliance concern in good faith, or is considering reporting such a concern, shall be subject to disciplinary action, up to and including termination.

What is the process for submitting a report? How do I set up a postbox?

To submit an anonymous or personalised report, start by clicking the ”Submit report“ button located on the top left side of our introduction page.

There are four 4 steps to the report process:

1. First, you will be asked to confirm that you read, understood and accept the information on processing of your personal data, and to respond to a security query.
2. On the following page, you will be asked about the category of your report.
3. On the report page, you can elaborate on your report in your own words and answer questions about the incident by simply selecting responses. You can type up to 5000 characters into the free text field, which corresponds to approximately a full page. You may also submit files of total up to five Megabyte to support your report. Please do bear in mind that documents can contain information about the author, consider redacting those details. Following the sending of your report, you will receive a reference number as confirmation that you have forwarded this report.
4. Please subsequently set up your own secured postbox. You will receive any feedback via this postbox, including questions on more details of the report, and answers to any questions from your side.

If you already have a secured postbox, you can access it directly via the ”Login“ button. First, you will have to answer a security query.

As long as you do not enter any data from which conclusions about your person can be drawn, the technology of the BKMS^® System will protect your anonymity.

How do I receive feedback and remain anonymous at the same time?

The overriding principle of the BKMS^® procedure in use is the protection of your identity. The system's anonymity protection function is certified by an independent body.

When setting up your secured postbox, please select your own pseudonym or username and password. Your report is kept anonymous through encryption and other special security routines. You will never be asked for compulsory personal information at any time during the reporting process. If you want to stay anonymous, do not submit any information that can be traced back to you. If possible, please avoid using a computer that has been provided by your employer to submit your report, as accessing the BKMS^® System might be traceable (even if the information entered into the system is not traceable).

Via the secured postbox, the dedicated examiner of the IMP will provide you with feedback on what is happening with your information or pose questions if details still need to be clarified – you will also remain anonymous during this dialogue. The IMP is interested in addressing compliance concerns, not in you as a whistleblower.

To establish communication with you, the IMP depends on your willingness to re-enter the system and access the report again. Please support the investigation by regularly opening your report and checking if any question / information has been posted by the IMP examiner.