Full Details of the Groupwide Whistleblower System

Integrity and compliance with laws and regulations, and the principles of our Code of Conduct have top priority and are the cornerstones of our corporate culture. In order to live up to these values and to avoid or minimize potential risks arising from violations of rules, it is crucial for potential violations by employees or external partners to be identified, clarified and remedied at an early stage and, in extreme cases, for disciplinary action to be taken.

With a view to fostering an open culture of error management and uncovering potential wrongdoing, WACKER operates a global, independent, impartial and confidential Whistleblower System. The Whistleblower System is available for reports about compliance incidents and concerns about data protection or human rights issues. Aside from Group Compliance and global compliance officers around the world, other specialists (e.g. group data protection officers) may be involved in the investigation.
The Groupwide Whistleblower System and the underlying code of conduct, guidelines and company policies are set out in the corresponding documentation.

Our Whistleblower System is based on key principles. These include protecting whistleblowers, those affected by the investigation and those supporting it. We respect the right of whistleblowers to confidentiality, we uphold the presumption of innocence and we ensure that all persons concerned are treated fairly in the investigations. Information received via the Whistleblower System is examined fairly, immediately and appropriately and treated with the utmost confidentiality. No measures are initiated to identify anonymous whistleblowers, However, reports made in bad faith or denunciations are treated as serious violations of the rules.
Special functions in Legal & Compliance, Finance, Corporate Audit, Human Resources and other units support the investigations as needed and to the extent required by the disclosure. An investigation is only initiated after careful examination of the disclosure and if there is reasonable suspicion of a violation of the rules.

The Whistleblower Process

Compliance-Incident Report

Whistleblower makes a report in the Whistleblower System
- Personal report (e.g. stating name / function )
- Anonymous report, with or without mailbox
Other reporting channels are possible (in person, via post, telephone or email)
Under the EU Directive and national whistleblower legislation, the whistleblower is protected (unless the report is a denunciation)

Delegation and Handling

Group Compliance reviews the report and the information provided
If necessary: translation, drafting in of relevant departments and units within the company
Where possible, communication with the whistleblower to clarify questions and obtain relevant documents and evidence

Investigation of the Disclosure

Group Compliance or relevant business units carry out the investigation
If necessary, committees are set up
Review and discharge of relevant reporting obligations
Review of submitted documents and evidence related to the disclosure
Conducting of relevant interviews and discussions

Next Steps

Appropriate measures are initiated, including changes to processes, expansion of control measures and, in extreme cases, disciplinary action
Communication of relevant reports to appropriate units in the company (Board of Management / Audit Committee)
Feedback to the whistleblower

Compliance-Incident Report

Our company provides various channels for employees, business partners, customers and other third-parties to disclose violations of rules at any time and in any language. The information is received by WACKER Group Compliance or, depending on the disclosure, by the appropriate departments. These ensure that thorough and proportionate investigations are carried out confidentially and promptly.

The qualified and experienced team at WACKER Group Compliance investigates every report of potential wrongdoing thoroughly and deals with it systematically in accordance with company guidelines. Group Compliance confirms to the whistleblower that it has received the report and then proceeds to review its content. This includes clarifying questions about the reported disclosure and gathering available facts, especially from the whistleblower.
If this preliminary evaluation indicates a reasonable suspicion of a violation of the rules, an investigation is initiated within the business division concerned. The results of the investigation are then analyzed by Group Compliance and by other relevant company units (such as Human Resources or Legal) and appropriate measures are initiated.
If the disclosure does not indicate a serious violation of the rules, the case may be referred to an appropriate unit within the WACKER company concerned. This unit then will then independently investigate and assess the case, possibly under guidance from WACKER Group Compliance. Whistleblowers or employees concerned may contact WACKER Group Compliance at any time to inquire out about the status and outcome of the investigation. Where legally permissible, the outcome is also communicated on the basis of the need-to-know principle. The processing time varies, however, with the subject under investigation.

Potential violations of the Code of Conduct for Suppliers and Business Partners by business partners, suppliers and other third-parties, including risks and violations relating to human rights and environmental obligations, may also be reported to Group Compliance. WACKER Group Compliance informs the responsible departments, which then handle the disclosure in the appropriate manner. This includes taking necessary measures to minimize or eliminate violations and/or risks.
Your choice of reporting channel determines how WACKER AG or selected service providers handle the personal data you provide in your report. These data are processed as part of the disclosure process. If you have chosen a direct reporting channel (email, telephone, in person), you will find further information on data protection on the WACKER homepage. If you submit your report via the WACKER Whistleblower System, you will find further information there as part of the data protection notice.

Our Whistleblowing Channels, Contact Persons and Key Contact Points

Our Whistleblower System provides the following channels for reporting potential violations by employees or external partners so that our company can investigate quickly and respond appropriately. This does not infringe your legally protected right to contact the competent authorities.

WACKER Whistleblower System (24/7 - Reporting in Person or Anonymously)

Whistleblowers around the globe can access the WACKER Whistleblower System, available 24/7 in several languages, to report potential compliance violations. These include white-collar crime, such as corruption or antitrust law, data protection issues and risks and violations relating to human rights and environmental protection obligations or other internal and legal regulations. Whistleblowers have the option to provide their name or to submit information anonymously. All submitted information is treated confidentially. Even if their preferred language is not offered in the reporting channel, whistleblowers may submit reports in any language. Our Whistleblower System is operated by a third-party on external, certified servers based in Germany. This ensures that whistleblowers can submit information to us anonymously and in a non-traceable manner.

Contact Persons and Contact Data (Email / Post / Compliance Help Desk)

Internal and external whistleblowers can report potential violations of rules or risks directly and confidentially to WACKER Group Compliance or other authorized bodies (for data protection / human rights issues / human resources) at any time and in any language.

The authorized persons can be reached in person, by telephone or by email.

Share your concerns with us

To the Whistleblower System

Responsible:

Wacker Chemie AG

Group Compliance
Gisela-Stein-Straße 1
81671 Munich
Compliance Helpdesk: +49 89 6279 3333
Email: compliance@wacker.com

Option for USA – Telephone Disclosures – Call Center
Call Center for USA: + 1 844 680 3968