QUAT²RO Whistleblower System

QUAT²RO is committed to responsible and sustainable company management. As such, integrity and legally compliant conduct are top priorities. QUAT²RO would therefore like to be informed at an early stage about any serious breaches of laws or internal company policies.

1. Misconduct by H&B employees

The aim is to avert damage to the company. Legal and regulatory violations damage the company and misconduct by individuals is to the detriment of the entire workforce. QUAT²RO’s good reputation and the trust shown in us by our customers and business partners are founded on our integrity and compliance with laws and regulations. Compliance also has a significant impact on employee wellbeing within the company and on the company’s sustainable economic success. To achieve compliance and identify breaches of laws and regulations in good time, immediately put a stop to them, and punish them where necessary, we need the help of each and every employee. Our company’s prompt and objective investigation of any reports of suspected violations is an essential part of this.

2. Supplier misconduct

For QUAT²RO, sustainability means simultaneously striving to achieve economic, social and environmental goals and holding these in equal stead. We want to live up to this responsibility on a global level and in our business relations. We conduct several measures to ensure that our suppliers meet our sustainability requirements. Should infringements still occur, however, we rely on being notified about them.

Suitable complaints procedures are a key part of our due diligence obligations and this whistleblower system can therefore be used to notify QUAT²RO about the following in particular:

1. Breaches of an applicable law
2. Environmental or human rights risks or infringements within a specific business unit and the supply chain (Sections 8 and 9 of the German Supply Chain Due Diligence Act (LkSG))
3. Breaches of Article 15 GDPR (right of access by the data subject)

These procedural instructions apply to the company HAVER & BOECKER OHG and its subsidiaries.

Legal (legal@haverboecker.com) and the affected department/business unit

1. Reporting via the whistleblower system on the QUAT²RO website.
2. All inquiries by data subjects that relate to the GDPR will be forwarded to the data protection officer as quickly as possible so that he/she can determine the legality of the inquiry plus identify and initiate any necessary further steps.
3. When handling reports, Legal is responsible for the following in particular (Article 12(4) of Directive (EU) 2019/1937):
   1. Providing any interested person with information on the procedures for reporting
   2. Receiving reports and documenting their content in the form AB-F-NM-01‘Whistleblower system reporting form’(Article 18, Directive (EU) 2019/1937)
   3. Acknowledging receipt of the report to the reporting person within seven days (Article 9(b) of Directive (EU) 2019/1937)
   4. Forwarding to the relevant responsible person(s) and manager(s)
   5. Initiating and implementing measures
   6. Assessing the effectiveness of the measures
   7. Maintaining contact with the reporting person in order to provide feedback and request further information where necessary. Feedback must be provided within a reasonable time frame, not exceeding three months from the acknowledgment of receipt or, if no acknowledgment was sent to the reporting person, three months from the expiry of the seven-day period after the report was made (Article 9(f) of Directive (EU) 2019/1937).
   8.  Closing the whistleblower report