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Whistleblower protection

With the Whistleblower Protection Act effective as of July 2, 2023, the Directive (EU) 2019/1937 of the European Parliament and Council from October 23, 2019, on the protection of persons reporting breaches of Union law, has been implemented into national law. The purpose of this law is, among other things, to protect whistleblowers who, in the course of their duties, gain information about specific violations covered by § 2 Whistleblower Protection Act.

If you have obtained such information, you may report it — anonymously, if preferred — to the designated reporting channels. Our internal reporting office at Feigen · Graf is available for this purpose. Should you prefer not to report within our firm, other reporting channels are equally open to you:

Internal Reporting Officer:

Phone: +49 (0) 69 77 01 96-86
Email: hinweisgeber@feigen-graf.de

External Reporting Officer:

Federal Office of Justice’s External Reporting Office
53094 Bonn
Phone: +49 228 99 410 66 44
Email: hinweisgeberstelle@bfj.bund.de

Which violations can be reported?

The scope of the Whistleblower Protection Act covers a wide range of violations that may be reported or disclosed to either our internal or an external reporting office. These may include:

  • Criminal offenses
  • Fines for breaches of regulations aimed at protecting life, health, or the rights of employees or their representatives
  • Violations of laws and regulations, such as those protecting personal data

You can find the full catalog of the substantive scope (§ 2 of the Whistleblower Protection Act) here. The whistleblowing system, however, is not intended for reports of incidents unrelated to professional misconduct. For such matters, please contact the appropriate authority (e.g., the police).

How to report violations?

There are no formal requirements for your report, meaning you may submit it in writing or verbally, anonymously if you wish. The contact options listed above are available for this purpose.

Upon request, a personal meeting with an authorized representative of the reporting office can be arranged within 14 days.

What happens after reporting?

Your report will be received and documented by an independent and qualified individual in a permanently accessible format. You will receive confirmation of receipt within seven days.

The report will then be reviewed by the internal reporting office, which may ask follow-up questions if necessary.

After evaluating the report, the reporting office may handle the case internally or, while maintaining confidentiality, forward it to an appropriate department within the company or an appropriate authority.

Provided that clarification of the issue or others’ rights are not compromised, you will receive feedback on any measures taken within three months.

How is the information handled?

If your report is made in good faith, the information you provide will remain highly confidential, disclosed only to those involved in the intake, investigation, or handling of the report.

Any further sharing of information that could reveal your identity will only occur with your prior written consent.

However, your identity may be disclosed in certain situations, such as:

  • In criminal proceedings at the request of law enforcement authorities
  • By order in an administrative procedure following a report
  • Due to a court decision.

Where this does not interfere with investigations or judicial proceedings, you will be informed in advance of any such disclosure.

What deadlines apply?

No specific deadlines are required from your side.

However, the reporting office must adhere to the following timelines:

  • 7 Days: Receipt of your report must be confirmed within seven days.
  • 14 Days: A personal meeting must be arranged within 14 days if requested.
  • 3 Months: Feedback on measures taken must be provided within three months, barring any conflicting reasons.
  • 3 Years: Documentation of your report will be deleted three years after the conclusion of the procedure.

What consequences might arise from reporting?

All reports falling within the scope of the Whistleblower Protection Act are legally protected. This means that you cannot be punished or subjected to other disadvantages for submitting a report.

The conditions for this protection are as follows:

  • Your report concerns a violation covered by the scope of the Whistleblower Protection Act, and
  • Your report is made in good faith, meaning you had sufficient grounds at the time of reporting to believe the information in your report was truthful.