FAQs

What is Whistleblowing?

The term “whistleblowing” describes the reporting of potential misconduct in companies, organizations, and authorities by employees or external parties (whistleblowers or informants).

Whistleblowing is not an easy task. It requires courage from the whistleblower to report misconduct. It also requires the company to accept that attention has been drawn to an internal weakness.

 

What exactly can/should be reported?

Violations of national and/or EU law can be reported through our reporting channel in German, English, Spanish, Italian, and Slovak. These include: violations of competition law, financial irregularities, providing false or misleading information to authorities, data protection breaches, environmental damage, non-compliance with workplace safety regulations, sexual harassment.

Matters such as bullying, concerns about compensation or remuneration, or social conflicts should not be reported here. Please contact your supervisor, the Human Resources team, or the works council in such cases.

 

Important recommendations for maintaining your anonymity

Do not report information from the company network or from your work computer/smartphone. If you attach files to your report, please note the following: Files may contain hidden information that could compromise your anonymity.

Before sending, ensure that attached files do not contain such information (document creators, EXIF data in images, etc.). If you are unsure whether your files contain such information, copy the text of your attached document into the report text instead. Alternatively, create a screenshot of the attachments and attach that instead. Please note that attaching voice messages may potentially limit your anonymity.

 

Why should I submit a report?

The goal is to prevent damage to our company. Honesty, integrity, and lawful compliance behavior form the foundation for Knill Energy’s reputation. They also build trust with our employees, customers, and business partners. All our employees are experts in their profession and good observers. Therefore, your reports are very welcome.

 

Tips for submitting a good report

For a report to be processed quickly and appropriately, it is important that it be as specific as possible. It is helpful if it contains the following information:

  • Which persons are affected?
  • What happened?
  • How often did the incident repeat?
  • Where did the incident occur?

 

What happens after submitting a report?

The person who submitted a complaint through the whistleblowing portal will receive confirmation of receipt within 7 days. All reported information is immediately investigated. Appropriate follow-up measures are taken to remedy the misconduct if justified by the investigation. Depending on the case, an investigation team will be assembled.

The whistleblower receives information about further steps in processing the case within 3 months. This includes follow-up measures taken.

 

What principles does the Knill Energy Group follow regarding “Whistleblowing”?

Confidentiality

Alleged violations can be reported confidentially by the whistleblower. The whistleblower can report the incident by revealing their identity or anonymously. The whistleblower’s reports about alleged violations are transmitted directly to the Whistleblowing Team. They are only made accessible to other persons to the extent necessary to conduct an appropriate investigation.

Acting in Good Faith

Anyone reporting an alleged violation through our whistleblowing portal must act in good faith. They must have reasonable grounds to believe that the information indicates a violation. Early warnings are also welcome to prevent violations.

However, all allegations that prove to be malicious or knowingly false are considered serious misconduct. This has employment law consequences.

No Retaliation or Other Sanctions Against Whistleblowers

It contradicts the values of the Knill Energy Group if someone is punished for reporting an alleged legal violation in good faith. There must be no retaliation or other sanctions within the company against whistleblowers who have acted in good faith. If an employee violates this principle, it has employment law consequences up to and including termination of employment.

 

WHISTLEBLOWING PRIVACY POLICY

Purpose of Processing

We have established a whistleblower system. The whistleblower system enables contact with us to report information about compliance and legal violations. Whistleblowers do not need to fear retaliation. Insofar as legally permissible, reports can generally be made without providing personal data. We process personal data insofar as it is disclosed to us. This is to review the report made through the whistleblower system and to investigate the alleged compliance and legal violations.

 

Data Processing According to Art. 13 GDPR

We process data that the whistleblower provides to us through their own statements in the context of the report.

 

Data Processing According to Art. 14 GDPR

We also process data of persons whom the whistleblower identifies in the course of reporting violations. This includes name data or functions of persons who caused the violation. It also includes name data or functions of persons who are affected by a violation. We process descriptions of behaviors or actions of the affected person in connection with the reported misconduct that could contribute to their identification.

 

Personal Data, Forwarding and Legal Basis

The use of the whistleblower system is possible without providing personal data, insofar as legally permissible. However, personal data may be voluntarily disclosed within the whistleblower process. This includes information about identity, first and last name, country of residence, telephone number, or email address.

When using anonymous communication with us, IP address and current location are never stored. After submitting a report, the whistleblower receives access credentials to the online portal mailbox. This enables continued protected communication with us.

To fulfill the aforementioned purpose, it may be necessary for us to transmit personal data to external bodies. These include law firms, criminal or competition authorities, within or outside the European Union.

We process personal data, insofar as we have received it, to the extent necessary for fulfilling legal obligations in terms of whistleblower protection. This is based on Art. 6 para. 1 lit. c GDPR as well as local data protection laws.

 

Responsible Body

As part of the Knill Group, we use the whistleblowing online portal jointly with Knill Energy Holding GmbH, Eisengasse 25, 8160 Weiz. We are jointly responsible for the processing of personal data. Affected persons can assert their rights with both us and Knill Energy Holding GmbH.

The whistleblower system (hintcatcher) is provided by our data processor, product kitchen GmbH, Rehsteige 12, 73035 Göppingen, Germany. A corresponding data processing agreement has been concluded with them.

 

Duration of Storage

We store personal data only as long as necessary for processing your report or we have a legitimate interest in storing your personal data. Storage may also occur beyond this if required by national or European legislators to fulfill legal obligations, such as retention requirements.

Personal data that is not needed for processing a report is neither collected nor stored by us. It will be deleted immediately if necessary.

After completion of the investigation, all reports and associated data are archived for a period of 5 years. Please note that the period in Germany is 3 years. After expiration of this period, we ensure the irrevocable deletion or anonymization of all data. Furthermore, retention occurs as long as necessary for already initiated administrative or judicial proceedings.

 

Your Rights

Data subject rights according to Art. 13 to 21 GDPR do not apply to persons affected by a report according to Directive (EU) 2019/1937 if this is necessary for the protection of the whistleblower or for the investigation of reports. These rights include: right to information, right of access, right to erasure, right to object. For reports outside the scope of the HSchG (Austrian Whistleblower Protection Act) or HinSchG (German Whistleblower Protection Act), the general data protection regulations apply.

If you believe that we have violated national or European data protection law in processing your data and thereby violated your rights, you have the right to lodge a complaint with a data protection authority. In Austria, this is the Austrian Data Protection Authority:

  • Address: Barichgasse 40 – 42, 1030 Wien
  • Telephone: +43 1 52 152-0
  • Email: dsb@dsb.gv.at