Compliance in accordance with the Whistleblower Protection Act

KESS BERLIN GmbH Whistleblower Protection Act

Integrity, reliability, respect and trust are top priorities for KESS BERLIN. These values are an integral part of our corporate behaviour and important prerequisites for our corporate success and for the trust of our employees, customers, business partners and shareholders.

KESS BERLIN does not tolerate any violations of applicable law, internal guidelines or the KESS BERLIN Code of Conduct. It is therefore important to find out as quickly as possible about potential misconduct by our own employees or suppliers and to prevent it.

To this end, Group Compliance operates an independent, impartial and confidential whistleblower system for the entire KESS BERLIN GmbH. Employees and third parties, including customers and suppliers, have the opportunity to report possible violations via confidential reporting channels and thus contribute to their clarification.

Principles

The cornerstone of the whistleblower system is the principle of fair proceedings. This also includes the possibility of anonymous reporting and communication.

KESS BERLIN will not take any measures to learn the identity of anonymous whistleblowers. Discrimination against whistleblowers and all persons who contribute to the investigation of potential misconduct within the company will also not be tolerated.

Investigations are always conducted with the utmost confidentiality and with the anonymity of the whistleblowers protected. The presumption of innocence naturally applies to those concerned until an offence has been proven. Information is processed in a fair, swift and protected procedure.

How are reports processed?

Group Compliance checks all incoming reports for possible serious breaches of regulations by employees or suppliers of KESS BERLIN GmbH.

The reports are processed promptly and analysed carefully and systematically. If there is an initial suspicion of a possible offence, a suitable (internal or external) body is commissioned to investigate the case. The results of the investigation are then evaluated by Group Compliance and, if misconduct is found, a recommendation for sanctions is issued. If necessary, the criminal prosecution authorities are informed.

Whistleblowers are informed promptly about the processing status and the outcome of a possible investigation in accordance with legal requirements.

Submit a report

Our whistleblower system offers various ways to report potential misconduct.

Irrespective of this, there is a statutory right to contact the competent authorities at any time, as described below.

1. ONLINE REPORTING CHANNEL: COMPLIANCE HELPLINE

It is possible to submit a report via the internet-based, multilingual communication platform Compliance Helpline. The system is confidential and protected. KESS BERLIN uses a whistleblower system from Deloitte provided by the CTS Eventim Group for this purpose.


Incoming reports are first reviewed by Deloitte analysts, summarised in a report and promptly forwarded to the responsible department (Group Compliance) at CTS Eventim and KESS BERLIN.

Group Compliance then examines the information and, where possible and necessary, initiates an investigation.

Process:

1.1 Report

The whistleblower, whether external or internal, has three options for reporting.

  • Completely anonymous: Neither Deloitte nor KESS BERLIN knows the identity of the whistleblower.
  • Confidential: Only Deloitte knows the identity
  • Limited confidentiality: Deloitte and the responsible office (Group Compliance) at KESS BERLIN know the identity.

    1.2 Processing at Deloitte

    Qualified Deloitte employees accept the report. At the request of the whistleblower, the report will be anonymised and made available to the responsible department (Group Compliance) at CTS Eventim and KESS BERLIN as a report. Data that is not relevant will be deleted.

    1.3 Processing by the responsible department (Group Compliance) at CTS EVENTIM

    All whistleblower reports are processed by the responsible office (Group Compliance) at CTS Eventim and KESS BERLIN. To the extent possible and necessary, the latter will initiate an investigation.

    SUBMIT A MESSAGE

    2. VIA E-MAIL

    Group Compliance can be contacted by e-mail at compliance@kessberlin.de.

    3. POSTAL, TELEPHONE AND IN PERSON (in English)

    Postal address:

    KESS BERLIN GmbH
    Compliance
    Rosenthaler Straße 40-41
    10178 Berlin
    Germany

    Tel. +49 030 767 580 400

    Please make an appointment in advance by emailing compliance@kessberlin.de.

    4. EXTERNAL REPORTING PATHWAY (for Germany)

    According to the German Whistleblower Protection Act (HinSchG), it is also possible to contact external reporting centres at any time. However, internal reports are often processed more quickly and directly.

    Further information on the reporting channels can be obtained from the contact persons at Group Compliance using the contact details above.

    Detailed information on the options for external reporting is also available from the Federal Office of Justice at BfJ - Hinweisgeberstelle (bundesjustizamt.de).

    Other external reporting offices are listed with the German Federal Financial Supervisory Authority (‘BaFin’) and the German Federal Cartel Office, among others.

    Status: 30 January 2024