Compliance.

Through our compliance management system, we ensure that legal requirements, internal policies and standards are met. For our employees as well as for our customers and partners. Respect, integrity and responsibility are essential elements of our corporate culture.

CODE OF CONDUCT.

Our Code of Conduct provides binding guidelines and defines our standard for lawful and responsible conduct. It describes our behavior towards business partners and the public, but also with regard to our internal dealings with each other. 

The contents of our Code of Conduct do not end at our internal company borders. For this reason, Marbach also expects its suppliers and consultants to comply with the requirements of the Code of Conduct and to commit contractually to this.

COMPLIANCE MANAGEMENT SYSTEM.

To ensure compliance with laws and rules in the company, we use an electronic compliance management system. This serves as an essential element to meet the growing compliance requirements and to monitor them efficiently.

DATA PROTECTION.

The protection of your privacy when processing personal data as well as the security of all business data is an urgent concern for us, and which we take into account in our business processes. Data protection and information security are part of our corporate policy. We treat the data confidentially and process them in accordance with the legal regulations as well as our data protection statement.

If you have any questions about data protection, please contact our data protection officer Dirk Lübbermann by e-mail (Dirk.Luebbermann@marbach.com) or by phone at +49-7131 918-228.

WHISTLEBLOWER SYSTEM.

Our whistleblower system offers, not only all employees of the Marbach Group, but also third parties, a confidential contact for enquiries as well as information regarding compliance issues or violations.

... is the clarification of your enquiry and/ or your information.

You would like to give us information about situations that have arisen because of possible rule violations, instances of dishonesty, possible weaknesses in the process, areas of risk or opportunities for improvement by employees or business partners?

Here we rely on open communication. In the first instance, you as an employee contact your boss. If this is not possible for you, our employees or third parties are welcome to contact our whistleblower representative. If you do not wish to disclose your identity, we will of course process enquiries or information anonymously.

 

Compliance issues: 

  • Compliance with laws 
  • No bribery and corruption
  • No discrimination and harassment
  • Occupational health and safety, no child labor
  • Information security, data protection
  • Environmental protection

 

We follow up all information and do not tolerate any discrimination against persons who report to us. This applies even if, upon closer examination, the information does not prove to be justified or substantiated, unless such information was provided in a blatantly defamatory manner.

 

Our integrity and adherence to rules is everyone's business. In serious cases, rule breaking and dishonesty can threaten individual jobs or even the entire company. That's why it is important for every employee to pay close attention and not look away. Any noticeable irregularities that indicate violations of rules and laws or indicate dishonesty should be reported, and advice sought if there is any uncertainty about an employee's own behavior or that of their colleagues.

Our aim is to identify potential problems at an early stage to take appropriate action in good time. Finally, it is irrelevant how and in what form relevant information reaches us. Even a question can reveal a need for improvement.

For your enquiries/ information, please contact our whistleblower representative directly. 

The whistleblower representative will assess:

  • Whether it is an advisory question that can be answered immediately. If so, the response will be initiated through your chosen channel of communication. This may include follow-up questions to further clarify the facts of the matter, which are necessary to properly understand and answer the question.
  • Whether the matter indicates possible misconduct, weaknesses or opportunities for improvement that require further investigation. Appropriate further actions will then be initiated in accordance with the company's procedures.
 

Contact person: Mrs. Silke Matter 

Availability: Tue, Wed, Thu from 8 am - 12 pm

Telephone: +49-7131-918-180 

Postally: Karl-Marbach-Str.1 / 74080 Heilbronn

Email: whistleblower-DE@marbach.com 

 

You will be free to remain anonymous. The exchange of information using the whistleblower system will be confidential. If you wish to receive a personal response, please let us know.

Irrespective of this, we do not tolerate any form of discrimination against persons who report information to us. This also applies if information do not prove to be justified or substantiated upon closer examination, unless such information were made in a blatantly defamatory manner.

If your information leads to the discovery of serious rule violation by yourself, this of course does not protect you from the consequences of the then appropriate measures to be undertaken under labor law or, if applicable, also criminal law. When deciding on this, however, the person's information that led to the clarification of rule violations and the prevention of further risks, can be taken into account.

For the purpose of reporting the whistleblower system saves the information you provide, as well as assessment by category and significance and  depending on the significance of the matter  also a brief description, any response given or the processing result and the conclusions drawn from it.

Insofar as personal data is involved, it is only saved within the framework of data protection law.

If you want to be informed about the result after your enquiry/ information has been processed, please provide us with your contact details such as name, address, phone number, email address.

For reasons of fairness, affected employees will be informed about the given information. The reason for this is that we maintain open communication at Marbach. The situation is different if there is a risk of collusion or if other employees could be put under pressure or disadvantaged if they are informed.

No information will be disclosed even at the insistence of a superior. Both the initial recipients of the enquiry/ information and any departments within the company that may be involved in further processing are obligated to maintain confidentiality. This also means that persons who have not been assigned the task of processing may not access the enquiry/ information or any related investigations results.

Investigations are carried out when there are information of misconduct, weaknesses or opportunities for improvement, i.e. also in the case of requests for advice that contain such indications. Otherwise, your information would remain without any follow-up. The company is obliged to investigate all alleged violations in an appropriate manner.

If you provide more detailed information on the facts or attach documents to your notice, you should be aware that this may result in your identity being revealed. 

Third parties such as investigating authorities, the trade supervisory authority, public prosecutor's office or antitrust authorities may examine enquiries/ information and the results of further investigations.

State authorities have access to all information available in the company within the scope of their investigative powers. For example, the public prosecutor's office or antitrust authorities may, in the course of investigative proceedings based on court orders, demand the surrender of all documents that are available in the company relating to a specific case and also conduct related investigations. The company can avert such seizure orders or search measures by handing over the relevant documents. In case of doubt, this also includes the information available/ saved in the whistleblower system on a specific issue with the investigating authorities.

Exception: If the information from the whistleblower system is only available at a law firm that acts as ombudsman and initial recipient of the enquiries or information on the basis of an advisory relationship, it is covered there by special seizure and search protection for attorney-client information.

In such cases search or seizure should therefore not be possible in practice.

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