Whistleblower Portal
An Open Corporate Culture and “Open-Door Policy”
At the Knill Group, an open corporate culture and an “open-door policy” are already being practiced. Nevertheless, there may be cases in which someone wishes to report legal violations related to our company in a protected environment – possibly even anonymously.
Through our whistleblower portal, violations of national and/or EU law can be reported. These include, for example: violations of competition law, financial irregularities, false statements to authorities, data protection breaches, environmental damage, non-compliance with workplace safety regulations, sexual harassment.
FAQs
What is whistleblowing?
The term “whistleblowing” refers to the disclosure of (potential) misconduct in companies, organizations, and public authorities by employees or external parties (so-called whistleblowers).
Whistleblowing is not an easy task – neither for the whistleblower, who must find the courage to report misconduct, nor for the company, which must accept being made aware of an internal weakness.
What exactly can/should be reported?
Through our reporting channel, violations of national and/or EU law can be reported in German, English, Spanish, Italian, or Slovak. These include, for example: violations of competition law, financial irregularities, false statements to authorities, data protection breaches, environmental damage, non-compliance with workplace safety regulations, sexual harassment.
Matters such as bullying, dissatisfaction with pay, or social conflicts should not be reported here. In such cases, please contact your supervisor, the Human Resources team, or the works council.
Important recommendations for maintaining your anonymity
Do not submit reports from the company network or from your work computer/smartphone. If you attach files, please note: files may contain hidden information (e.g., metadata) that could reveal your identity and compromise your anonymity. Before sending, ensure that attached files do not contain such information (document authors, EXIF data in images, etc.). If unsure, copy the text into the report field instead or create screenshots of attachments. Note: voice recordings may limit your anonymity.
Why should I submit a report?
The goal is to protect our company from harm. Honesty, integrity, and compliance with laws and regulations form the foundation of Knill Energy’s good reputation and the trust of our employees, customers, and business partners.
All our employees are experts in their field and good observers – your input is therefore highly valued.
Tips for submitting a good report
For a report to be processed quickly and appropriately, it should be as concrete as possible. Helpful details include:
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Which persons are involved?
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What happened?
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How often did the incident occur?
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Where did the incident take place?
What happens after submitting a report?
The whistleblower receives confirmation of receipt within 7 days. All reports are promptly investigated, and appropriate follow-up actions are taken if justified.Depending on the case, an investigation team will be formed. The whistleblower receives information on further steps (including follow-up measures) within 3 months.
Principles of Knill Energy Group regarding whistleblowing
Confidentiality
Reports of (suspected) violations can be submitted confidentially, either anonymously or with disclosure of identity. Reports are only shared with others if necessary for proper investigation.
Good faith
Whistleblowers must act in good faith and have reasonable grounds to believe that the information indicates a violation. Early warnings are also welcome. Malicious or knowingly false reports are considered serious misconduct with employment consequences.
No retaliation
Retaliation or sanctions against whistleblowers acting in good faith are against Knill Energy Group’s values. Employees who violate this principle may face consequences up to termination of employment.
Whistleblowing System
1. Purpose of processing
We have established a whistleblowing system enabling reports of compliance and legal violations without fear of retaliation. Where legally permissible, reports may also be submitted anonymously. Personal data provided will only be processed to examine the report and investigate suspected violations.
2. Data processing under Art. 13 GDPR
We process data provided directly by the whistleblower during reporting.
3. Data processing under Art. 14 GDPR
We also process data of persons named in the report (e.g., names, functions, descriptions of behavior relevant to the alleged misconduct).
4. Personal data, transfer, and legal basis
Use of the system is possible without providing personal data. If provided voluntarily, data may include name, country of residence, phone number, or email. IP addresses and location data are never stored when using the anonymous channel. Access credentials for secure follow-up communication are provided.
Data may be shared with external parties (e.g., law firms, authorities) inside or outside the EU if required. Legal basis: Art. 6 (1) lit. c GDPR and local data protection laws.
5. Responsible entity
As part of the Knill Group, we use the online whistleblowing portal jointly with Knill Energy Holding GmbH, Eisengasse 25, 8160 Weiz. Both entities are jointly responsible for data processing. The portal (hintcatcher) is provided by our processor, product kitchen GmbH, Rehsteige 12, 73035 Göppingen, Germany.
6. Storage period
Personal data is stored only as long as needed to process the report or where there is a legitimate interest. Legal retention requirements may extend storage. Data not required will be deleted immediately. After investigation, reports and related data are archived for 3 years, after which they are deleted or anonymized, unless needed for ongoing proceedings.
7. Your rights
Data subject rights (Art. 13–21 GDPR) do not apply where necessary to protect the whistleblower or the investigation (Directive (EU) 2019/1937). For reports outside the scope of the Whistleblower Protection Act, general data protection law applies.
If you believe your data has been processed unlawfully, you may lodge a complaint with Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen:
- Address: Kavalleriestraße 2 – 4, 40213 Düsseldorf
- P.O. Box: 20 04 44, 40102 Düsseldorf
- Phone: +49 211 384240
- EMail: poststelle@ldi.nrw.de