We have established a corporate culture based on performance, autonomy and trust. It combines  appreciation and pleasure in what we do with consistency and transparency in decision making.

As a key element of our corporate culture, we are committed to adhere to our code of conduct. The principles it covers naturally include compliance with existing laws and regulations as well as compliance and adherence of the principles of honest and impeccable business conduct.

The success of our Corporate Group is also due to the good reputation our company enjoys with the general public, our business partners and public agencies. It is our company’s good name and its integrity that form the basis for the trust which is essential to the business we do. Integrity must be external and internal and be shaped by people. The honest and impeccable behavior of management as well as employees is of prime importance here. 

When problems or conflicts arise, we are committed to dealing with them personally and at eye level. Thus we can and also should openly report a suspected violation of compliance and address it directly – where necessary, not only by reporting it to a line manager but also to the next level up. We maintain a corporate culture in which the open reporting of possible violations should be the rule.

There are various ways you can report a violation of compliance. In many cases, a good first step is to speak with the person affected. We see an open culture of communication as a key element of well-established compliance. 

• If a personal conversation is not possible or you feel it is not an option for you, please contact your line manager. As a third party, your appropriate business contact at Vorwerk should be informed.
• If you have the feeling that – for whatever reason – you cannot talk to your line manager or business partner, then please contact the local HR or compliance department. We are committed to dealing with reports personally and at eye level.  

To give employees who may nevertheless feel that they cannot openly name a suspected violation of compliance to their available personal contacts (line managers, People & Culture, employee representatives), we have set up a whistleblower platform. This platform enables people to submit an anonymous report and it can also be used by business partners and independent sales advisors.  

With our whistleblower system, we offer people the opportunity to report concerns regarding a suspected violation of our code of conduct, our policies and applicable laws and regulations in the strictest confidence. Some, but by no means all, examples of this are: 

• violations of antitrust law
• money laundering or violations of trade sanctions
• violations of data protection regulations
• environmental, health and safety concerns
• human rights violations
• violations of Vorwerk’s code of conduct
• suspected fraud (misappropriation or misconduct in financial reporting)
• bribery and corruption
• abuse of power and conflicts of interest
• bullying or discrimination
• (sexual) harassment
• disclosure of confidential business information
• reprisals against whistleblowers who express their concerns in good faith 

The whistleblower system is not used to report, for example:

• routine employment problems (e.g., in relation to leave days, salary and performance reviews); please discuss these with your line manager or HR
• customer complaints in connection with, for example, a late delivery or a problem with order collection
• private (legal) disputes
• accusations that are known to be false. Anyone making such an accusation may be liable to prosecution

You want to report a human rights or environmental risk or violation at our company or within our supply chain, but don’t know who you to turn to? 

• If you have information about a human rights or environmental risk or violation, it can be a good move to go straight to your manager, business contact or the competent department to discuss the matter. 
• If you cannot turn to your manager or business partner about your concern – for whatever reason at all – please contact the local human resources or compliance department. Our policy is to deal with such information personally. 
• However, for any staff members who feel they cannot talk openly about a suspected human rights or environmental violation or risk with the people they could potentially approach personally (managers, People & Culture, employee representatives), we have set up a second whistle-blower platform in line with the Act on Corporate Due Diligence Obligations in Supply Chains (LSG) especially for their use. That platform is available around the clock and gives you the opportunity to file reports with complete anonymity. It can also be used by business partners and self-employed trade representatives. 

All reports received will be treated as confidential. Information will only be forwarded to a limited number of people on a strictly need-to-know basis. Every whistleblower acting in good faith is protected. 

Reports accusing an individual of possible violations of compliance may have serious consequences for that person, so please only use the whistleblower system as a last resort.

Your report will be logged in a case management system (CMS) and processed by a clearance team of the Group Corporate Governance department of Vorwerk SE & Co. KG.

We send you a confirmation of receipt within seven days. We run a preliminary check on each report to evaluate and assess whether further review and investigation is required. We will contact you should we require further information in order to complete our review. It goes without saying that we conduct our preliminary checks and reviews confidentially, independently, fairly and without prejudice to any of the parties involved. You will receive a response within three months after sending the confirmation of receipt.

As a matter of principle, we always inform a person that they have been the subject of a complaint.