Internal reporting office under the Whistleblower Protection Act (HinSchG)

On July 2, 2023, the Whistleblower Protection Act (HinSchG) came into force, which implements the so-called Whistleblower Directive (Directive (EU) 2019/1937) into German law. The essential aim of this law is to ensure comprehensive protection for persons who report violations of law and breaches of rules in companies and authorities.

The establishment of an internal reporting office is a voluntary and optional measure. Employees, suppliers, and customers of GGM have the opportunity to report potentially serious misconduct at the workplace or violations of human and environmental rights.

If you provide us with tips via the Internal Reporting Office, you enable us to investigate the matter and take appropriate measures. We understand that reporting incidents is often a courageous step and may be associated with concerns about experiencing negative consequences from reporting. Therefore HinSchG regulates the protection of so-called whistleblowers. People who provide tips are protected by the law from disadvantages arising from their reporting. Reprisals in the professional context, such as e.g. disadvantages in promotions, warnings, dismissals or other forms of disadvantages, are not permissible due to whistleblowing.

People who want to report misconduct can contact either internal or external reporting office.

If internal action can be taken effectively against any violations, please primarily contact the Internal Reporting Office. You thereby help to safeguard the reliability and integrity of GGM Gastro International GmbH and to ensure compliant behavior as well as fair interaction. Even after an internal tip submission, the possibility of (further) external tip submission remains.

1. Violations that are criminally punishable,
2. Violations that are punishable by fines, to the extent that the violated provision serves to protect life, body or health or the protection of the rights of employees or their representatives,
3. other violations of federal and state laws as well as directly applicable acts of the European Union and the European Atomic Energy Community.

These include, among others:

• Combating money laundering and terrorist financing,
• Product safety and conformity,
• Road safety,
• Environmental protection,
• Radiation protection and nuclear safety,
• Promotion of the use of energy from renewable sources and energy efficiency,
• Food and feed safety,
• Consumer rights and consumer protection,
• Protection of privacy in electronic communications, for the protection of the confidentiality of communications, for the protection of personal data,
• Information technology security.
• Violations of nationwide and uniformly applicable regulations for clients regarding the procedure for awarding public contracts and concessions and the legal protection in these procedures upon reaching the relevant EU thresholds,
• and other financial and tax violations.

Please note:

• The Internal Reporting Office is not responsible for general complaints.
• If you suspect alleged data protection violations, please report them directly to the data protection officer of GGM Gastro International GmbH.
• The Internal Reporting Office is not intended for handling acute emergencies or danger situations.

Your tip will be confirmed by the head of the reporting office within 7 days of receipt. The examination and evaluation of the tip will take place within 3 months. You will subsequently be informed about the actions taken or planned follow-up measures, provided that this information does not affect internal investigations or inquiries and does not violate the rights of the persons named in or affected by the report.

Your data are usually treated confidentially and not disclosed to third parties. However, if it is required due to a legal obligation or to further investigate the violation you reported, personal information will be disclosed to third parties only after we have contacted you in advance.

Providing personal information as a whistleblower is voluntary. However, providing contact details can facilitate communication between you and the reporting office and speed up the process of clarifying the tip. The Internal Reporting Office also handles anonymous tips.

If you provide personal information, by submitting the tip you consent that we may process and store these data for the purpose of clarifying the tip and contacting you. You may withdraw your consent at any time for the future.

With these privacy notices, GGM Gastro International GmbH takes responsibility for the processing of personal data by the Internal Reporting Office under the Whistleblower Protection Act in accordance with its information obligation pursuant to Articles 13 and 14 of the EU General Data Protection Regulation (EU GDPR). Regarding the other terms used, personal data, processing, data controller, third party, etc., reference is made to the definitions in Article 4 of the EU GDPR**.**\n\n1. Contact details\n\n1.1. Name and contact details of the data controller\n\nGGM Gastro International GmbH\n\nManaging Directors: Ferit Inan & Ömer Elma\n\nWeinerpark 16 \nD - 48607 Ochtrup\n\nTelephone: +49 (0) 2553 – 72 20 – 0 \nFax: +49 (0) 2553 – 72 20 20 – 200 \nEmail: info@ggmgastro.com \nwww.ggmgastro.com\n\n1.2. Whistleblowing office\n\nWebsite: Whistleblower Protection System\n\n1.3. Contact by mail\n\nWhen contacting by mail, please mark your letter on the envelope as confidential. If you would like a personal meeting, please let us know via one of the above channels.\n\n1.4. Contact details of the Data Protection Officer\n\nOur Data Protection Officer can be reached by post at the address of the data controller and by e mail at datenschutz@ggmgastro.com.\n\n2. Processed personal data and purposes\n\nIn the context of submitting a tip and the handling of tips by the Internal Reporting Office, personal data about you will be collected and processed for the following purposes:\n\nFor tip submission\n\n- If applicable: name and contact details\n- Personal data that are the content of your report.\n\nFor the initiation of follow up measures\n\n- Personal data that are necessary to take follow up measures.\n\n3. Legal basis for data processing\n\nThe legal basis for processing personal data for the above purposes is Art. 6(1)(c) GDPR in conjunction with § 10 Whistleblower Protection Act.\n\n4. Data transfers\n\nYour personal data, which GGM Gastro International GmbH processes for the purposes named in Section 2, are generally not disclosed to third parties. In exceptional cases, data transfers to third parties may occur on the basis of a legal permit, for example under the provisions of the Code of Criminal Procedure (StPO) to law enforcement authorities for the investigation of criminal offences.\n\n5. Retention periods\n\nData processed for the purposes named in Section 2 are generally deleted three years after the completion of the proceedings in accordance with § 11 Abs. 5 HinSchG or - if they are paper documents - destroyed.\n\n6. Your rights as a data subject\n\nYou, as a data subject, may at any time exercise the rights granted to you by the EU GDPR:\n\n- the right of access to know whether and which data about you are processed (Art. 15 GDPR),\n- the right to rectify or complete the data concerning you (Art. 16 GDPR),\n- the right to erasure of the data concerning you in accordance with Art. 17 GDPR,\n- the right, in accordance with Art. 18 GDPR, to request a restriction of processing of the data.\n\nIn addition to the above rights, you have the right to file a complaint with the data protection supervisory authority (Art. 77 GDPR).