WHISTLEBLOWER SYSTEM

WHISTLEBLOWER

Tilly Holzindustrie has a whistleblower system in accordance with the Whistleblower Protection Act (HSchG) in order to give potential whistleblowers the opportunity to confidentially point out existing grievances or even illegal behaviour within our company, which are covered by the factual scope of application of the HSchG (see below in the FAQ).

Reports from whistleblowers are not received by Tilly Holzindustrie, but centrally by our partner CONFIDA. All reports can also be submitted anonymously if desired. A procedure agreed with CONFIDA guarantees that all incoming information is treated confidentially and that the greatest possible protection of your identity is maintained.

All information to be submitted via the Tilly Holzindustrie whistleblower system must currently only be sent to CONFIDA by e-mail, at the following e-mail address:

whistleblower.tillyholzindustrie@confida.at

PLEASE EXPLICITLY INDICATE IN ANY REPORT WHETHER YOU WISH TO REMAIN ANONYMOUS. IN THIS CASE, YOUR IDENTITY WILL NOT BE PASSED ON TO TILLY HOLZINDUSTRIE UNDER ANY CIRCUMSTANCES, UNLESS THERE IS A DELIBERATE FALSE REPORT OR OBVIOUS MISUSE OF THE TILLY HOLZINDUSTRIE WHISTLEBLOWER SYSTEM

Please familiarize yourself with the information below before submitting a report:

  • Who is entitled to use the Tilly Holzindustrie whistleblower system?

All persons who have become aware of internal company processes or information that indicate possible grievances, irreconcilable or even unlawful conduct that are covered by the material scope of the Whistleblower Protection Act (see below). This includes, for example, employees of Tilly Holzindustrie, including interns, volunteers, applicants and former employees, as well as our contractual partners (e.g. suppliers, customers and other business partners) as well as all involved third parties who are in any way connected to Tilly Holzindustrie.

  • When should I consider using the Tilly Holzindustrie whistleblower system?

Before using the Tilly Holzindustrie whistleblower system, we ask you to check in detail whether, in view of all circumstances – especially with regard to facts that do NOT fall within the factual scope of application of the Whistleblower Protection Act, or due to a possibly rather minor scope or limited economic significance of the grievance or misconduct to be pointed out – you should not also send your report directly to an employee or to an employee or to the Whistleblower Protection Act. your supervisor or the management of Tilly Holzindustrie.

  • Which facts are covered by the material scope of the Whistleblower Protection Act?

The grievances or behaviors you point out should be related to the following areas:

  • Public procurement;
  • financial services, financial products and financial markets, as well as the prevention of money laundering and terrorist financing;
  • Product safety and compliance;
  • Road safety;
  • Environmental protection;
  • radiation protection and nuclear safety;
  • Food and feed safety, animal health and animal welfare;
  • public health;
  • Consumer protection;
  • protection of privacy and personal data and security of network and information systems;
  • Prevention and punishment of criminal offences according to §§ 302 to 309 of the Criminal Code (StGB), Federal Law Gazette No. 60/1974 (= corruption offences);
  • infringements of rights to the detriment of the financial interests of the Union within the meaning of Article 325 of the Treaty on the Functioning of the European Union (TFEU) and in accordance with specific definitions in relevant Union policies;
  • infringements of internal market rules within the meaning of Article 26(2) TFEU, as well as infringements of Union rules on competition and state aid, and infringements of internal market rules in relation to acts that infringe corporate tax rules or in relation to agreements aimed at obtaining a tax advantage contrary to the object or purpose of corporate tax law.
  • What should be done with regard to facts that are NOT covered by the material scope of the Whistleblower Protection Act – can I also report them via the Tilly Holzindustrie whistleblower system?

No. The material scope of application of the Whistleblower Protection Act does NOT cover, for example, allegations of bullying, violations of the Working Hours Act or violations of the Federal Equal Treatment Act (e.g. sexual harassment in the workplace, etc.).

If you have information about grievances or behaviour with regard to facts that are not covered by the material scope of the Whistleblower Protection Act (see catalogue above), you are requested to forward your report directly to your direct supervisor (or, if the direct supervisor is the person affected by your tip-off, to his superior) or, in case of doubt, directly to the management.

  • What do I have to do to ensure that my tip is treated anonymously?

If you wish to submit a report anonymously, please indicate this explicitly in your report. However, make sure that you submit the report from an untraceable e-mail address, i.e. if possible from your private e-mail address or e-mail address set up specifically for the report.

In any case, please also remember the access to the e-mail address you have chosen in order to remain available for questions from CONFIDA until your report has been completed. Your anonymity will also be preserved in this case and your identity will not be passed on to Tilly Holzindustrie under any circumstances, unless there is a deliberate false report or obvious misuse of the Tilly Holzindustrie whistleblower system.

  • What else should I consider when reporting?

Describe the facts you have shown as concretely as possible and relate them. You may include any documents and/or other material that may have come into your possession in your report, for example as an attachment to the e-mail or only by reproducing it verbatim or in spirit.

Please also note the privacy policy on our website (https://www.tilly.at/de/datenschutz).

According to § 24 HSchG, the submission of knowingly false information constitutes an administrative offence, which is punishable by a fine of up to 20,000 euros, in the event of a repeat offence up to 40,000 euros. In addition, deliberately submitted false reports as well as any other misuse of the Tilly Holzindustrie whistleblower system can also result in further consequences under employment law and/or criminal law as well as claims for damages.

  • What happens after I submit my report?

CONFIDA will confirm receipt of your report immediately – but in any case within 7 days of receipt of the report. At your express request, a meeting with you must take place within 14 days to discuss the notice.

In any case, please continue to stay in contact with CONFIDA afterwards in order to remain available for questions. To do this, check the email account you use regularly (but at least once a week) for messages.

In any case, CONFIDA will get back to you within 3 months, for example to inform you about the current status of your report or about any measures you have already taken.