Information regarding Whistleblowing

1.    Introduction

Compliance with the law, internal policies and the principles of our Code of Conduct is a highest priority for the Sebapharma Group. It is of fundamental importance for us to learn of possible misconduct and to ensure that it is clarified.

The companies of the Sebapharma Group listed below are subject to the provisions of the HinSchG:

•    Sebapharma GmbH & Co. KG
•    Maurer Pharma Nord GmbH

The established whistleblower process guarantees the most extensive protection for both the whistleblower and the person(s) concerned. This also includes the fact that we offer the option of contacting and reporting anonymously.

An investigation is only initiated after a careful review of the information and the existence of concrete evidence of a serious breach of the rules and laws. This is carried out in strict confidentiality and as part of a fair, swift and confidential process.

2.    Contact informations internal reporting office

Reports can be made to our external whistleblower officer, Lena Ludwig or her representatives, either by e-mail to hinweise-sebamed@psw.de or by telephone on +49 159 046 130 67.

We provide encryption for messages sent by e-mail. See section 8.

The anonymity of the whistleblower will be ensured to the Sebapharma Group and will only be disclosed with prior express consent of the whistleblower.

3.    Reports of violations that guarantee whistleblower protection

The following legal violations can be reported via our internal reporting office:

•    Tax fraud
•    Money laundering
•    Inconsistencies in the awarding of public contracts
•    Product and traffic safety errors
•    Violations against environmental protection
•    Risks for public health 
•    Violations of consumer and data protection
•    Violations of criminal law
•    Violations that constitute an administrative offense and are contrary to the purpose of the standard, specifically the protection of life, limb or health, as well as the protection of the rights of employees

4.    Content of a whistleblower report

The more information, evidence and proof you can provide us with, the better your report can be processed. You can use the following information as a guide:

•    Which company/location is involved?
•    Your name and position or what is your connection to the company?
•    What would you like to report?
•    When was the incident?
•    Who is involved in the incident? (persons, department, etc.)
•    Are there any other witnesses?
•    If you have evidence or proof, e.g. documents, photographs, etc., you can provide these with your report.
•    Finally, if you wish, please let us know how the whistleblower officer can contact you to ask questions and inform you of the outcome of the investigation.

The report can also be submitted anonymously/pseudonymously. The anonymity of the whistleblower will be preserved and only disclosed with prior express consent.

5.    Misuse of the reporting office

The Sebapharma Group reserves the right to file a criminal complaint or take other appropriate sanctions in the event of knowingly false reports and willful misuse.

6.    External reporting offices

You can also contact external reporting offices at the respective monitoring authorities. For contact information, please visit the websites of the relevant authorities.

 
7.    Procedure of a case

After receiving of the report, the whistleblower will get a confirmation of receipt from the whistleblower officer within 7 days. Unless there is no means of contact or the report was made anonymously.

After 3 months, the whistleblower will be informed of any follow-up measures planned or already taken. These must be proper follow-up measures in accordance with §18 HinSchG. These may include internal investigations or possible measures to rectify the problem.

If no sufficient evidence is found despite investigations, the whistleblower will be informed that the case has been closed due to a lack of evidence. In such a situation, the whistleblower is free to take the matter to the external complaints office. This reporting office has 6 months to conclude the proceedings.

8.    Safety of processing

For the implementation of the process, appropriate protective measures of both a technical and organizational nature have been taken. 

To enable you to send a secure message, we provide you with the public keys for encrypted e-mail communication below.
 

9.    Changes

Please note the current status of this page, as we regularly make changes to the content as part of our review processes.

 

 

Status: November 2023