The HEIDELBERG Group stands for integrity, reliability and fairness. For the HEIDELBERG Group, compliance means not only acting in accordance with applicable laws and internal regulations, but rather shaping the corporate culture. The integrity of HEIDELBERG Group’s employees, managers and governing bodies build the basis for the good image and reputation in the public and reflect also the trust into HEIDELBERG Group’s goods and services.
Each individual of the HEIDELBERG Group contributes to the long-term success of the company and job security by acting and behaving with integrity. Compliance misconducts as well as violations against applicable laws and internal regulations are strictly pursued and punished.
The Compliance Management System (CMS) of the HEIDELBERG Group is orientated towards the Auditing and Assurance Standard 980 of the Institute of Public Auditors in Germany, Incorporated Association (IDW). With its seven basic elements, it constitutes significant structural, organizational, process-related requirements in regard to the operational implementation in the HEIDELBERG Group. Therefore, the group-wide CMS includes measures, controls and processes to ensure that the day-to-day actions and decisions of HEIDELBERG Group’s employees, managers and governing bodies are compliant with applicable laws and regulations as well as internal values and guidelines. Hereby, a key focus lies on the compliance risk management, to identify, measure and manage risks at an early stage. Through thus, compliance misconducts or violations are identified early and prevented in a timely manner. Furthermore, the employees, managers and governing bodies of the HEIDELBERG-Group are advised and addressee-oriented trained.
The Group-wide compliance function is the responsibility of the Chief Financial Officer. Its tasks are performed by the Chief Compliance Officer (CCO) and the Compliance Office. They are supported in this by regional compliance officers based around the world.
For further questions please contact our Compliance Office.
The Code of Conduct of the HEIDELBERG Group builds the basis for the CMS of the HEIDELBERG Group. It is both a binding framework as well as orientation for day-to-day actions and decisions within the HEIDELBERG Group. Within this framework, each individual is called upon to take responsibility and to act with integrity, reliability and fairness. The managers of the HEIDELBERG Group are called upon to act as role models hereby and to support their employees in complying with our Code of Conduct.
The HEIDELBERG Group stands for free and fair competition in all business relationships with customers, suppliers, business partners, and competitors as well as for responsible and lawful day-to-day actions and decisions. Therefore, the HEIDELBERG Group's business partners are carefully selected and reviewed. These business relationships build the basis for the entrepreneurial success of the HEIDELBERG Group.
The HEIDELBERG Group expects its business partners to share and promote the values, principles, and policies of the HEIDELBERG Group. The Business Partner Code of Conduct of the HEIDELBERG Group serves as the basis for a compliance, continuous and long-term partnership. It stipulates an operational framework for the business partners of the HEIDELBERG Group for their day-to-day business actions and decisions.
In order to report potential compliance misconduct or compliance violations at an early stage and to ensure a complete investigation of any allegations, the HEIDELBERG Group has implemented direct and trustworthy reporting channels for employees, customers, suppliers, and business partners.
The HEIDELBERG Group provides its internal and external whistleblowers with various reporting channels. Any type of compliance violation can be reported confidentially and, if desired, anonymously either digitally or by telephone via the SpeakUp whistleblower system. The ombudsman is another neutral reporting office. This guarantees that our employees, customers, suppliers and business partners can provide information about possible violations confidentially and, if desired, anonymously. Protecting all internal and external whistleblowers is a matter of course for the HEIDELBERG Group.
Furthermore, possible misconduct can also be reported directly, via the Board of Management, the Works Council or via managers to the compliance function, in particular to the Compliance Office and the worldwide Regional Compliance Officers.
The SpeakUp whistleblower system can be used to report any kind of compliance violation confidentially and, if desired, anonymously, either digitally or by telephone. Reports can be submitted around the clock in various languages. The whistleblower system is technically managed by an independent operator and the reports are processed by the company's internal Compliance Office. Below you will find the answers to how SpeakUp works.
https://heidelbergerdruckmaschinen.speakup.report/speakup
Data protection information on the Whistleblower System (pdf)
In principle, any type of compliance violation can be reported, in particular any suspicion of fraudulent or unethical behavior that constitutes a serious violation of Heidelberg's Code of Conduct, as well as any violations of applicable laws. Violations at Heidelberg suppliers can also be reported. Examples include:
The report should describe the situation as accurately as possible. The more precise the information, the easier and quicker it is to investigate the report. As a guide you can use the basic questions “what”, “who”, “where”, “when” and “how”.
We will treat all submitted reports strictly confidential. If desired, the report can be submitted anonymously. Even if the report is submitted anonymously, the whistleblower will receive access data, in particular a case number. The case number can be used to track the status of the case and communicate with the investigator.
Web-based report can be submitted via the following link:
https://www.speakupfeedback.eu/web/heidelbergerdruckmaschinen
First, the whistleblower must select the respective country and then the desired language. Then an access code, which is displayed on the page, must be entered. Now the whistleblower can select whether a new report is to be submitted or whether a report that has already been submitted is to be processed further. When submitting a new report, it can be entered in a free text field and attachments can also be uploaded.
After entering the message, a password must be created. Together with the case number, which is then displayed, the password is required in order to be able to log into the system again later. In this way, feedback on case processing can be provided and further information about the case can be entered into the system.
Country-specific telephone numbers have been set up for telephone reports (telephone list as PDF). First, the access code for Heidelberger Druckmaschinen AG must be entered. This is 34693.
Please note: Calls are not answered by humans, but the message is recorded on tape. This is then transcribed, translated and forwarded to the relevant department. As this is a free-spoken message, we strongly advise you to write down the text of the message before calling. After the message has been spoken, an individual case number is created. Together with the password you have set yourself, the case number is necessary for staying informed about the processing of the case and to be able to communicate with the responsible investigator. The access data must be treated confidentially.
All reports are first processed by our platform provider and translated if necessary. The reports received are then reviewed by the Compliance Office to determine whether an investigation is required. All reported cases are properly documented. In each case, the reporting person receives an acknowledgement of receipt for their report within 7 days.
Not every report needs to lead to the initiation of an investigation. In the event of a refusal, a brief explanation will be sent to the person providing the information. Reports that do not lead to an investigation can occur in the following cases:
If an investigation is initiated, the case will be assigned to the appropriate investigator based on the facts. The investigator conducts the investigation and takes all internal or external steps to give due consideration to all the circumstances of the case. This includes, but is not limited to, establishing facts, reviewing the case, and communicating with the whistleblower or other parties involved. After completing the investigation, the investigator creates an internal report and a proposal for further action, which is sent to the Compliance Office.
The ombudsman serves as a neutral reporting office. Our employees, customers, suppliers and business partners can contact ombudsman confidentially and anonymously if they wish to report potential compliance misconduct or compliance violations in the HEIDELBERG Group.
These are external lawyers who are professionally bound to secrecy in their function and are not permitted to pass on any information about the whistleblower to the HEIDELBERG Group without the express consent of the whistleblower. After its own due examination, the ombudsman decides whether and to what extent information received is to be communicated to the HEIDELBERG Group. The whistleblower does not incur any costs by using the ombudsman's office.
Attorney
Felix Rettenmaier
Corneliusstraße 34
60325 Frankfurt/Main, Germany
Phone: +49 69 8740 30018
E-Mail: ombudsmann@rettenmaier-frankfurt.de
Attorney
Dr. Carolin Weyand
Schumannstrasse 62
60325 Frankfurt/Main, Germany
Phone: +49 69 874 03 00-10
E-Mail: ombudsmann@rettenmaier-frankfurt.de
Compliance-Office
Heidelberger Druckmaschinen AG
Gutenbergring
69168 Wiesloch, Germany
E-Mail: Complianceoffice@Heidelberg.com
