Rules of procedure for the complaints procedure of the Bundesdruckerei Group

Our Complaints Procedure is always available to any person, whether internal or external, who wishes to submit a tip or a complaint about actual or alleged grievances within the Bundesdruckerei Group or along its supply chains. If individual legal claims are to be asserted, an effective power of attorney can be requested. Every report will be checked and processed regardless of this.

The following complaint channels can be used to submit tips or complaints:

Our online whistleblower system for recording a complaint or a tip is available via the Internet at the address https://report.whistleb.com/en/bundesdruckerei at any time.

Whistleblowers may incur telecommunication costs for internet use.

If whistleblowers use this online tool to file a complaint, they will receive access data to the online tool when they use the system for the first time, which will enable further communication with the whistleblowers – anonymised if they wish.

• An answering machine with a voice recording function is available at any time for whistleblowers at the telephone number +49 (0)800-1810989 to submit a complaint or a tip by phone. The required company code is 388201.
  
  Telecommunication costs may be incurred by the whistleblowers for telephone use.

Complaints can also be sent by post or in-house mail to the

• Bundesdruckerei GmbH
  
  Compliance (Tip)
  
  Kommandantenstraße 18
  
  10969 Berlin

or

• by e-mail to compliance@bdr.de.

Personally: Whistleblowers are asked to make an appointment in advance via compliance@bdr.de if reporting in person.

All complaint and information channels accept reports in German and English. The Bundesdruckerei Group will endeavour to process messages in other languages as well.

All actual and alleged violations of legal requirements, the Code of Conduct and the Code of Conduct for Business Partners can be reported under the Complaints Procedure.

Likewise, the subject of a report may involve human rights, environmental risks or violations of obligations along the entire supply chain of our Group companies as well as in our own business area.

In order for a complaint or a tip to be dealt with appropriately and for grievances to be rectified quickly, the information must be as specific as possible.

We list questions here that may help in formulating a report, although answering them is not a prerequisite for processing the report.

First, we need a description of what happened, in chronological order if possible. The following questions should be answered:

• What happened?
• When did it happen and is it still going on?
• Where did it happen?
• Who is affected by the incident?
• What is the damage?
• Who could be responsible for the incident or what happened?
• Which regulations have been violated?
• How is this related to the Bundesdruckerei Group?

Tips and complaints can be submitted without proof or evidence. However, if and to the extent that the whistleblower has evidence, such as photos, videos, documents and/or details of other witnesses, these can be very helpful for processing.

In addition, we ask for information on how further contact should be arranged.

• Is there a desire for anonymity or confidential treatment of the whistleblower’s identity, e.g. by not disclosing the name?
• How should further communication take place?

Last but not least, expectations regarding possible preventive or remedial measures can be communicated.

Each incoming report is documented internally and given an individual file number.

Regardless of the chosen communication channel, reporting parties will receive an acknowledgement of receipt of their tip or complaint no later than 7 days after receipt. If contact details have been provided, this will be done in writing, by e-mail or electronically via the digital whistleblowing system, depending on which communication channel has been chosen for the report.

The processing status can be requested at any time via the selected communication channel; in the case of the online whistleblower system, the identification number and password are required (see 2.2 above).

In addition, the reporting person will receive feedback within three months after receipt of the report is acknowledged to indicate any follow-up action planned or already taken. It should be noted that this may only be possible to a limited extent if it affects internal enquiries or investigations or if it affects the rights of the persons who are the subject of the report or are named therein.

The employees of the Compliance Division entrusted with the implementation of the complaint procedure will examine the facts communicated with the filed complaint. First, the complaint received is classified and prioritised by topic and severity.

Further verification is then carried out by the responsible office within the Bundesdruckerei Group, depending on the Group company or supply relationship concerned. The person making the tip or complaint will be informed of the responsible department.

The staff members in charge of performing the Complaints Procedure will fully investigate the facts of the case and ensure that all leads are investigated appropriately.

If verification is not possible due to a lack of sufficient information, the whistleblower will be contacted for further information if this is possible.

The circumstances will be discussed with the whistleblower and also with anonymous whistleblowers via the online whistleblowing system as far as is possible and necessary.

We aim to determine whether there are sufficient indications that make a violation of rules, a breach of law or the risk or violation of human rights or environmental obligations in our own business or along our supply chains appear likely.

Then, any further legally required investigation and clarification measures, such as supplier discussions or audits or formal internal investigations, will be taken in compliance with data protection law.

The processing time is determined by the case and can take from a few days to several months, depending on the complexity of the case. However, the Bundesdruckerei Group endeavours to complete the processing as soon as possible.

The whistleblower will be informed of the conclusion of the complaint procedure.

If, after the facts have been clarified, discussed and investigated, the employees entrusted with carrying out the Complaints Procedure are convinced that

• no violations of legal requirements, the Code of Conduct or the Code of Conduct for Business Partners and
• no human rights and environment-related risks or violations of human rights-related or environment-related obligations in our own business or along the supply chain of our Group companies

have occurred, the Complaints Procedure will be discontinued. The whistleblower will be informed of this in writing or by e-mail.

The Complaints Procedure will also be discontinued if an investigation or verification is not possible, either because of a lack of sufficient fact-based information or because the reporting person cannot be contacted.

If

• violations of legal requirements, the Code of Conduct or the Code of Conduct for Business Partners or
• human rights or environment-related risks or violations of human rights or environment-related obligations in our own business or along the supply chain of our Group companies

are confirmed during the investigation, appropriate follow-up measures (preventive and corrective measures) will be initiated by the responsible unit in the company. For example, this may include appropriate disciplinary measures in individual cases, the adjustment of processes or even the termination of business relationships under certain circumstances.

If complaints about human rights or environmental issues reveal abuses in the business unit, countermeasures will be taken and monitored to the extent legally permissible in order to minimise the risk immediately or to end the violation.

The Complaints Procedure described here is free of charge for reporting parties.

It should be noted that any costs and expenses incurred in connection with the use of the Complaints Procedure, such as telecommunication costs, travel expenses or costs for legal advice, will generally not be borne by the Bundesdruckerei Group.

The Bundesdruckerei Group shall be free to also offer a procedure for consensual resolution – in particular, arbitration or mediation proceedings – at any stage of the Complaints Procedure. The whistleblower will be free to participate in this consensual resolution procedure. The details of the consensual resolution procedure will be discussed jointly by the parties and regulated in a separate agreement that is to be concluded.

All information will be treated confidentially unless there are legal obligations to report information to authorities or legal exceptions to this confidentiality requirement.

The anonymity and confidentiality of whistleblowers’ identity will be maintained throughout the process. This protection will also include persons who are the subject of a report and other persons named in the report.

Personal information that allows identification may only be disclosed if strictly necessary for investigating the report and in accordance with data protection requirements.

Discrimination, intimidation or hostility along with other reprisals against whistleblowers, complainants or persons who cooperate with investigations to the best of their knowledge and belief are inadmissible and will not be tolerated.

Any whistleblowers who have the impression that they are suffering intimidation or reprisals as a result of their report should contact Bundesdruckerei GmbH’s Compliance Division or the department that is processing their report.

Compliance concerns involving intimidation or reprisals for making a report or a tip will also be investigated according to the principles outlined in these Rules of Procedure.

Knowingly making false reports of violations with the aim of deliberately and untruthfully accusing another person constitutes a compliance violation and will be punished with appropriate measures.

If whistleblowers are affected who are employees of a direct or indirect supplier, Bundesdruckerei will endeavour to make appropriate arrangements with the supplier.

The persons entrusted with implementing the Complaints Procedure are impartial, i.e. they are independent in how they perform their task and not bound by instructions.

Investigations comply with applicable law, including data protection law.

Investigations are carried out neutrally and objectively. Incriminating and exculpatory information is taken into account. Persons suspected of misconduct are presumed innocent.

Only legal investigation methods are used, and only legally usable information is factored in. The principle of proportionality applies, meaning that investigative measures must always be suitable, necessary and appropriate to fulfil the purpose of the investigation.

Wherever employee representatives have participation rights, the necessary bodies will be involved accordingly.