The observance of laws and regulations is a central aspect of our business conduct.

Who can submit a report?

Anyone can submit a report. For example, this applies to our own employees, our customers/clients, service providers/suppliers and other business partners, as well as the public in general. Anyone who wishes to submit a report is referred to in general as a “whistleblower”.

What can I report?

You can report potential compliance violations (that have occurred or that are very likely to occur) within the following categories, for example:

• Business crime (e.g. fraud, bribery, corruption, etc.)
• Competition and antitrust law
• Data protection and information security
• Insider trading and market manipulation
• Regulatory and supervisory
• Money laundering and financial sanctions
• Human rights or other ESG aspects (environmental social governance)
• Sales-related principles and policies
• Other actual or potential serious violations, such as violations of the Munich Re code of conduct or of labour laws

Where can I submit my report?

The ERGO Group has implemented this secure and confidential whistleblowing system, which also satisfies the requirements of the EU Whistleblower Directive (Directive (EU) 2019/1937).

You can access the whistleblowing system from anywhere in the world.

If you are employed by a company which is part of the ERGO Group, you are also welcome to report known or suspected compliance violations to your direct supervisor, the HR department or the local/regional compliance officer. Naturally, potential compliance violations can also be reported to the competent local authorities.

To whom can I direct my report?

You can select whether to direct your report to Compliance ERGO, the central ombudsperson at ERGO and/or – if mandated by law – to the respective (compliance) officer(s) at the local companies. Your report will only be visible to the specific (compliance) officers with whom you opted to share the information.

How can I submit a report, and how do I set up a postbox?

To submit a report either anonymously or by name, first click on the “Submit Report” button at the top of our homepage.

The reporting process consists of five steps:

1. First, you will be asked to read some information on the protection of your anonymity and respond to a security query.
2. On the following page, you will be asked to indicate the category of your report.
3. You will then be asked where you would like to direct your report. You can select whether to direct your report to Compliance ERGO, the central ombudsperson at ERGO or – if mandated by law – to the respective (compliance) officer(s) at the individual local companies. Your report will only be visible to the specific (compliance) officers with whom you opted to share the information.
4. On the submission page, you can then enter your report in your own words and answer questions about the incident by simply selecting responses. You may enter up to 5,000 characters in the free text field, which corresponds to a full A4 page. Please note that your report may be composed in any language. You can also attach files to your report (up to 5 MB). Please note that documents can contain information about their author. After submitting your report, you will receive a reference number to confirm that you have submitted this report.
5. You will then be asked to set up your own secured postbox. We can use this postbox to provide you with feedback, answer your questions and keep you updated about the status of your report. We therefore encourage you to set up a secured postbox since this will make it possible for the responsible (compliance) officer to contact you with additional questions, if necessary.

If you already have a secured postbox, you can open this directly via the “Login” button. First, you have to answer a security query here as well.

You can choose whether to remain anonymous or share your name.

If you wish to submit your report anonymously, please take care not to provide any information that could reveal your identity. As long as you do not enter or attach any data that could reveal your identity, your anonymity will be protected in technical respects by the BKMS^® System.

If you choose to share your name, we guarantee that your identity will only be disclosed to the persons directly entrusted with the case management.

What happens after I submit my report? Will I receive feedback?

The responsible (compliance) officer will process your report by evaluating the information and initiating an investigation, if necessary.

If you have chosen a communications channel via which the responsible (compliance) officer can contact you (e.g. by setting up a secured postbox in the whistleblowing system), you will receive confirmation of receipt of your report within seven days and additional feedback within three months at most.

We therefore encourage you to set up a secured postbox within the whistleblowing system since this will make it possible for the responsible (compliance) officer to contact you with additional questions, if necessary.

How can I receive an answer and still remain anonymous?

The BKMS^® System is designed to protect the identity of the whistleblower. The anonymity function of the system is certified and can be verified by you at any time.

When setting up your secured postbox, you should select your pseudonym/user name and password yourself. Only you can see this login information. If you lose your login information, please submit a new report and set up a new postbox. If possible, please provide the reference number of your original report. Because the postbox is new, you will not see the content associated with your original report.

Encryption and other special security measures have been implemented to ensure that your report remains anonymous at all times. At no time during the process will you be asked to disclose personal data. If you wish to remain anonymous, please do not provide any information that can be traced back to you. Please do not use a PC provided by your employer to submit your report.

The examiner responsible for your report will contact you via your secured postbox to update you on the status of your report or ask further questions if any points require clarification – your anonymity will continue to be protected throughout the process.

Is my report confidential/anonymous?

Yes, your report is confidential!

You can choose whether to remain anonymous or share your name.

If you choose to share your name, we guarantee that your identity will only be disclosed to the persons directly entrusted with the case management.

If you wish to submit your report anonymously, please take care not to provide any information that could reveal your identity.
Confidentiality and protecting you as whistleblower are our top priority and the guiding principle of our whistleblowing system, and all reports are processed on the basis of a strict “need to know” principle. Your report will only be visible to the specific (compliance) officers with whom you opted to share the information.

Should I fear reprisals due to my report?

No!

As long as you have justifiable reasons to expect that the reported information was true at the time of your report, you need not fear any reprisals in response to your report and any such attempt would itself be considered a serious compliance violation. Conversely, the intentional submission of a report known to be false also represents a serious compliance violation and could result in severe consequences under criminal and labour law.