WHISTLEBLOWING SYSTEM

What kind of whistleblowing can be done?

Through our whistleblowing system, you can bring to our attention not only whistleblowing under the EU Whistleblower Protection Directive 2019/1937 and the German Whistleblower Protection Act (valid as of July 2, 2023), but all legal, social and other compliance-related grievances in the business of MHG and its suppliers.

1. Examples of legal grievances

• Violation of human rights
• Violation of environmental regulations
• Corruption, bribery, acceptance of benefits
• Fraud, theft, embezzlement, deception, personal enrichment
• Discrimination, unequal treatment in the application process, etc. (violations of the General Equal Treatment Act/AGG)
• Data protection violations
• Accounting and bookkeeping violations
• Violation of employee protection regulations (incl. health and safety at work)
• Violation of export control regulations (embargoes, sanctions, etc.)
• Violations of competition or antitrust law (e.g. agreements with competitors, unfair business practices)
• Violation of contractual obligations
• Infringement of intellectual property (copyrights, trade secrets, patents, etc.)

2. Examples of social grievances

• Abuse of power
• Sexual harassment
• Other forms of harassment (verbal, physical or psychological)
• Bullying
• Racism, discrimination, unequal treatment among colleagues, by a superior or towards business partners
• Threats, coercion
• Compulsion, assault

3. Examples of other compliance-related grievances

• Violation of internal regulations and work instructions
• Violations of the Code of Conduct
• Defects in product design or material selection that may result in damage or problems in the use of the product

Which reports will not be processed?

Abuse of the whistleblowing system will not be tolerated. Grossly negligent or intentional false reports are not subject to whistleblower protection and may also lead to the whistleblower being liable for damages. Complaints of a commercial and technical nature do not fall within the scope of our whisteblowing system and are therefore not handled by our contact point. For these types of reports, please contact your respective contact person from our customer service team.

Who can be a whistleblower?

• Employees (including former employees), job applicants, temporary workers of MHG.
• Business partners such as customers, suppliers, service providers, etc. who have business dealings with MHG
• Other stakeholders such as non-profit organisations, municipal or environmental associations, etc.

How do I make a report?

If you would like to make a report, you can reach our internal contact point at This email address is being protected from spambots. You need JavaScript enabled to view it. or by telephone during our business hours at +49 (0) 2159 9189 7757.

The responsible employees are trained accordingly and can receive reports in German and English. In their function, they are independent of instructions and will always treat the information received confidentially. Please note, however, that we are not yet able to accept anonymous reports.
Your report should be as specific as possible. It is helpful to answer the following five questions: Who? What? When? How? Where?

As an alternative to the MMC Hartmetall GmbH whistleblowing system, you can also use the publicly accessible external reporting channels, e.g.:

1. Federal Cartel Office:
Information on cartel violations

2. North Rhine-Westphalia State Data Protection Commissioner:
Your complaint | LDI - North Rhine-Westphalia State Commissioner for Data Protection and Freedom of Information (nrw.de)

How is the whistleblower protected?

„Whistleblower protection is corporate protection“ - following this guiding principle of the Federal Ministry of Justice, we place special emphasis on protecting the whistleblower from reprisals as well as the confidentiality of his or her identity. This is not only in the interest of the whistleblower, but also in our own interest in a functioning early warning system. We only pass on the information received if and to the extent that this is absolutely necessary for the clarification of the facts. Whistleblowers do not have to fear any disadvantages of a business, disciplinary or other nature.

What happens after the report?

You will receive an acknowledgement of receipt within 7 days of receipt of your report. The report is then first subjected to a plausibility check, followed by the determination of appropriate follow-up measures. Follow-up measures can be, for example:

• Initiation of internal investigations, questioning of named witnesses
• Taking measures to remedy the problem (e.g. re-training of staff)
• Passing the case on to the competent authority, self-reporting, etc.
• Closing the case due to lack of evidence or other reasons

If necessary, you will be contacted by the contact point in the meantime to clarify open questions or uncertainties. It is therefore important that you can be reached at the contact details provided. At the latest after three months (calculated from receipt of the confirmation of receipt), you will receive feedback on the follow-up measures planned or already taken as well as the reasons for them.

All documentation of the procedure will be deleted no later than 3 years after the conclusion of the procedure.

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