Compliance

The main task of the ombudsman is the confidential receipt of information regarding violations of the Whistleblower Protection Act. The ombudsman is independent and autonomous and is not under any obligation to provide information to Wien Holding GmbH or the companies affiliated with it.

The ombudsman’s office is staffed by qualified employees of O.P.P-Compliance GmbH (O.P.P.), based in Wels. All employees of the ombudsman's office are subject to a statutory duty of confidentiality.

The Whistleblower Protection Act stipulates which matters can be reported to the ombudsman (simplified representation):

• public procurement,
• Financial services, financial products and financial markets as well as prevention of money laundering and terrorist financing,
• product safety and compliance,
• road safety,
• Environmental Protection,
• Radiation protection and nuclear safety,
• Food and feed safety, animal health and welfare,
• public health,
• consumer protection,
• protection of privacy and personal data and security of network and information systems,
• Prevention and punishment of criminal offenses (bribery, abuse of office, etc),
• Violations against the financial interests of the Union,
• smuggling,
• Tax fraud and cross-border VAT fraud,
• Subsidy Abuse.

The ombudsperson will point out that the topic is not covered by the Whistleblower Protection Act and let you know who to contact with your concerns.

Yes, the ombudsman’s office is an independent body. In the course of its activities, it will not receive or accept any instructions from Wien Holding GmbH or its affiliated companies.

All employees of the ombudsman's office are subject to a statutory duty of confidentiality, therefore the confidentiality and content of all communication between whistleblowers and the ombudsman's office is guaranteed at all times. It is possible to contact the ombudsman's office anonymously or have the ombudsman's office forward information anonymously to Wien Holding GmbH or to the group companies concerned.

If violations of the provisions of the Code of Conduct, legal regulations, or other guidelines and regulations are identified, a report should be made immediately to the relevant compliance office of the company. However, there are situations in which employees or other third parties cannot or do not wish to follow the general procedure. In these cases, employees or other third parties can turn to the ombudsman's office.

No, contact is always voluntary.

First of all, you should check whether you can submit your information via the ombudsman's office. A report should only be submitted to an external reporting office if it is not possible or reasonable to deal with the report in the internal whistleblower system or if such a report has proved unsuccessful or futile.
The reporting office of the Federal Bureau of Anti-Corruption (BAK) is available to you as an external office (https://www.bkms-system.net/BAK).

No, the ombudsman's office acts as a neutral party between Wien Holding GmbH and its affiliated companies and the employees or other third parties. Contacting the whistleblower does not create an attorney-client relationship.

Yes, no charges will be incurred.

• By telephone, dial +43 7242 306677 810
• with the online incident form www.meinhinweis.at/wienholdingkonzern or
• via email to hinweis@meinhinweis.at

As a rule, the incident report is analysed by an employee of the ombudsman's office, summarized and then forwarded anonymously to the compliance department of the company concerned. During the internal investigation, the responsible compliance unit will only involve persons who are absolutely necessary in order to clarify the facts. As part of the review, the information received is checked, for example by evaluating company data or interviewing accused persons. If further information is required to clarify the matter, the ombudsman's office will contact the whistleblower (unless the whistleblower submitted the report anonymously).

In cases where a report is not submitted anonymously, the ombudsman's office will only disclose the identity of the whistleblower to the company concerned if the whistleblower explicitly agrees to this. In all other cases, the identity of the whistleblower will be treated confidentially.

All data is protected at the ombudsman's office. Uninvolved third parties have no access to any of the data transmitted by you. Personal data that is not required for the processing of a tip or report may not be collected or must be deleted immediately. For more information, please refer to the privacy policy on the website of the whistleblower system.

If the whistleblower has made the report in good faith, there will be no negative consequences. In the case of knowingly given incorrect information, legal action can be taken against the whistleblower. Administrative fines of up to EUR 20,000.00, in case of repetition up to EUR 40,000.00, may be incurred.

Yes, the general and preferred procedures for complaints are still valid.

Yes, the ombudsman’s office will add new information to an existing report and take this into consideration when examining the facts of the case.

If further information is required to clarify a matter, the ombudsman's office will contact the whistleblower, if contact details have been provided.

The whistleblowing system provides legal, technical and organizational protection if you wish to remain anonymous.

To further increase your security, consider the following points:

• If you wish to remain anonymous, do not provide any personal data, such as your name or your relationship to those involved. Also, refrain from providing details that could allow conclusions to be drawn about your identity.
• When reporting an incident by mobile phone, dial #31# 0660 104 21 55 to supress your phone number.
• Make sure your internet connection is secure, indicated by the lock icon next to the address bar.
• If possible, go directly to the meinhinweis.at/wienholdingkonzern server, either by placing a bookmark on your introductory page, or by using the following link: https://www.meinhinweis.at/wienholdingkonzern/hinweis-geben-en/
• If possible, do not use technical devices such as PCs, laptops, smartphones or telephones provided by your company. An intranet connection in particular, i.e. a network connection from the company network or Wi-Fi, could endanger your anonymity.
• Use a private email address when submitting a report via email.

This will vary from report to report and cannot be said in general terms. In the case of ongoing investigations, the whistleblower will receive an interim report and a notification once the investigation has been completed, provided contact information was provided at the time of submission.
The whistleblower can contact the ombudsman to inquire about the exact status of an investigation at any time. This can also be done anonymously, stating the company, date of submission and content of the report, as well as stating the password named in the online form.