Company · Governance
Whistleblowing & Ethics Policy
ECO EFX Solutions GmbH is committed to ethical business conduct, integrity, transparency and compliance with applicable laws and internal policies. This policy explains how to raise concerns and how we handle them.
1. Who can report
Employees, business partners and other stakeholders are encouraged to report suspected misconduct, legal violations, conflicts of interest, corruption, discrimination, safety concerns or other unethical behaviour — in good faith.
2. What can be reported
- Corruption, bribery and improper gifts
- Fraud, embezzlement and financial manipulation
- Conflicts of interest
- Anti-trust or competition violations
- Data protection and information-security breaches
- Product safety and quality issues
- Manipulation or withholding of test results
- False or exaggerated product and environmental claims
- Environmental or occupational-safety violations
- Discrimination, harassment and inappropriate behaviour
- Violations of contracts, internal policies or applicable law
- Retaliation against whistleblowers
3. How to report
Concerns may be reported confidentially, in writing or orally, through any of the following channels:
Email: Show email
Ethics & Compliance contact: Michael Borg-Möller
Deputy: Fintan Early
External lawyer: Christian Baarz (Rechtsanwalt) — Show email
You may also report concerns to the competent external reporting authorities. Internal reporting is encouraged, but using an external channel remains your right.
4. Confidentiality & anonymity
We protect the identity of the reporting person and of anyone named in a report. Access is limited to the persons responsible for handling the case. Anonymous reports will be reviewed where sufficient information is provided. However, ECO EFX Solutions GmbH cannot guarantee anonymity when reports are submitted through ordinary email or telephone channels.
5. How we handle reports
We follow a clear, confidential process:
- Acknowledgement — we confirm receipt of a report within seven days.
- Assessment — we review each report objectively, follow up as appropriate and may request further information.
- Feedback — we provide feedback on planned or completed measures within three months of the acknowledgement.
- Action — where misconduct is confirmed, we take appropriate corrective and preventive measures and review whether processes, controls or policies need to be improved.
- Documentation — reports are documented and retained in accordance with statutory requirements, and deleted thereafter.
6. Protection from retaliation
Retaliation against individuals who raise concerns in good faith is not tolerated. Retaliation is itself a reportable matter under this policy.
7. Data protection
Personal data received through a report is processed in accordance with the General Data Protection Regulation (GDPR) and only for the purpose of handling the report. Further information is set out in our Privacy Policy.
8. Legal basis
This policy reflects the requirements of the German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG) and of EU Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.
9. Review
We review this policy periodically and update it to reflect changes in our organisation or in legal requirements.