1. Introduction

Misconduct in the Polybol – especially systematic misconduct – has not been tolerated in the past and will not be tolerated in the future.

Nevertheless, it cannot be ruled out that we observe behavior in our daily work that we judge to be misconduct or wrongdoing.

We have set up a system that gives employees of the Polybol as well as external contractors or other stakeholders the opportunity to report incidents that they judge to be misconduct or wrongdoing.

We would like to encourage you to participate! Make an active and valuable contribution so that we can jointly identify and remedy any misconduct and wrongdoing and thus meet the high standards we set ourselves.

2. What is to be reported?

Not every form of uncomfortable behavior is equivalent to misconduct or wrongdoing. Priority should be given to behaviors that constitute a criminal offence against the interests of the company or (may) constitute a serious offence. Any behavior that contradicts our behavioral guidelines (Polybol Code of Conduct as well as Polybol Group Organizational Guidelines) is also included – even if it is not a criminal offence.

3. Where to report?

Please report your indications of misconduct or wrongdoing via our web platform Polybol.com, our digital reporting system accessible via the Internet.

4. You can remain anonymous!

Your report and all communication can remain completely anonymous.

However, to ensure the effectiveness of the procedures for following up on reports and to facilitate further communication, we encourage you to provide your name. Keep in mind that an anonymous report can make it more difficult to verify misconduct if, for example, in the case of misconduct in the interpersonal area, the identity of the other party is not known or important supplementary information cannot be obtained. We therefore ask you to provide your contact details, especially if you believe that you have been affected by third-party misconduct.

Even if you wish to remain anonymous, please create a “secure mailbox” to enable further anonymous communication between you and the internal reporting office at Polybol.

Create a secure mailbox:

When you submit your report, you will have the possibility to create a secure mailbox for future inquiries. Please make use of this opportunity as we may not be able to close the case without further information from you.

When you create a mailbox, you will be assigned a case number and you will need to choose a password. You will need this case number and password to access the secure mailbox to check regularly if you have received any inquiries about your report. Please make sure to keep your case number and password. Without the case number and password you won’t be able to view anonymously reported case and further inquiries.

Regardless of whether you remain anonymous or provide your name, we ask you to create a mailbox. This makes it easier and safer for the internal reporting office at Polybol to communicate with you.

Reports can be made anonymously.

5. How detailed is to be reported?

Any notice should be as specific as possible. Please provide as much detailed information as possible about the facts of the case in your report. This is important to be able to assess the facts correctly. It is helpful if you include the five questions – Who? What? When? How? Where? – in your report. Documents that are already available and helpful for an assessment should be submitted (e.g., in person or via the web platform). No further data should be collected from you.

6. Key Points „Whistleblowing“

• Whistleblowing helps us to make improvements. Whistleblowing is no “denigration” but sharing information about misconduct or wrongdoing in order to remedy it.
• What misconduct should be reported? Any breach of our rules of conduct and any suspicion of criminal activity should be reported.
• When, how and where to you make a report? If you have reasonable grounds to believe that misconduct or wrongdoing has occurred, please report the relevant facts in as much detail as possible (background, course of events as well as names, dates, locations, other information and existing documents) to the Internal Audit department as the internal reporting office at Polybol (via the web portal https://polybol.com/polybol-integrity-line/Polybol.com, by telephone, by mail or in person).
• Confidentiality! Your reports and your personal information will be treated confidentially insofar and as long as this does not conflict with the purpose and progress of the investigation of your report. Your report may also be made completely anonymously. We will protect you and any person who cooperates in the investigation also from mere attempted discrimination, harassment, bullying, etc.