Information for whistleblowers

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Informationen für Hinweisgebende

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Informationen für Hinweisgebende

Careful handling of incidents.

Whistleblowers report concerns and incidents anonymously and securely.

The apt Group advocates a culture of trust, where employees can ask questions, seek advice, raise concerns and report suspected wrongdoing or illegalities. Our whistleblower system supports us in identifying potential problems, raising concerns and addressing abuses or wrongdoing directly.

Compliance with rules and standards is crucial to prevent harm to our company, our employees and external persons. In this way, we protect anyone who may be affected by misconduct within our organization. Therefore, compliance with laws and regulations is a top priority.

Through our whistleblower system, reports of misconduct and suspected wrongdoing or illegalities can be submitted in a safe environment – anonymously if desired. This system is available to both our employees and the temporary workers entrusted to us.

Upon receipt of a report, it is categorized depending on the risk to our company, our employees or third parties. Due to local requirements, the criteria of our whistleblower system may vary. Each report is therefore assessed individually upon receipt. An investigation is then initiated at the Group level or locally at the site, depending on the risk and details of the report.

The apt Group makes intensive efforts to process reports quickly and without unnecessary delays. At the same time, it is ensured that during the initial investigation and any subsequent investigation the reporter is given sufficient time to respond to questions and/or raise other relevant aspects of the case. The duration of a thorough investigation of a report varies depending on the scope and complexity and can range from several weeks to several months.

Reporters are protected to the fullest extent possible and their information is kept confidential. Defamation or harassment of reporters because of their report will not be tolerated at the apt Group.

Persons against whom allegations have been made will be given an opportunity to tell their side of the story as early as possible. Until it is proven that a violation has occurred, the presumption of innocence applies. We consider both incriminating and exculpatory information in our investigation and support the entire process of report handling, from receipt of the report to the conclusion of the proceedings. In doing so, we ensure the highest level of confidentiality and independence. In addition, we value fairness in our whistleblowing system, both to the individuals who give us reports and to those against whom allegations are made. The principle of proportionality is consistently observed, and in each case we assess what consequences are appropriate, necessary and proportionate.

Please note that reports without sufficiently concrete indications cannot be processed further for legal reasons. We would also like to remind you that knowingly false reports or defamation of colleagues in any case constitutes a violation of compliance and can potentially lead to legal consequences.

For specific reports of violations of law or violations related to the apt Group, please contact our whistleblower system via the following link.

Go to the whistleblower system

Technical Process

Our whistleblower platform allows you to report possible misconduct through a secure website. After leaving a message, you will receive a randomly generated case number and set up a personal password. Please keep this carefully to communicate with us. The case number allows you to read or listen to feedback and/or questions via the platform and, for example, communicate further about an issue. Electronic documents can also be uploaded.

If you have forgotten your case number and/or password, please send us your message again. You will then receive a new case number and can set a new password. For further communication with our team, please then use your new case number and your new password.

In addition, you can reach us at the following address:

apt Holding GmbH
Meldestelle
Rheinpromenade 11
40789 Monheim am Rhein
E-Mail:ethics@apt-alu-products.com

or by voice message via the telephone number +316 30354430.

Fundamental principles

Transparency and protection
As part of an open process, our complaints procedure contributes to the protection of our company, our employees, customers, business partners and other affected parties, in particular whistleblowers. Our system is based on a standardized and transparent process accompanied by confidential and professional handling of information and complaints.

Our goal is to investigate reports and complaints in a fair, balanced and transparent manner in order to resolve problems efficiently and effectively.

The following principles apply in detail:

Objectivity and impartiality.
Reports and complaints will be handled neutrally and objectively – with strict adherence to the presumption of innocence. The employee(s) responsible for conducting the proceedings act impartially without being bound by instructions.

Discretion
The employees conducting the procedures shall treat each case with the utmost confidentiality, especially when dealing with personal information. The identity of the person providing the information will not be disclosed unless they consent to the disclosure of their identity. Confidentiality also extends to individuals who are the subject of reports or complaints.

Protection of the whistleblower
It is prohibited and will not be tolerated to discriminate against, intimidate or hostile whistleblowers or those participating in investigations. Employers must henceforth prove that any form of disadvantage, such as a poor evaluation, transfer, demotion, dismissal, or disallowance of assignments is not the result of a whistleblower report. Nor may threats of disadvantage be made. The protection applies to reports made in a work-related context.

Involvement of the whistleblower
Every report and complaint is taken seriously by apt and the whistleblower is kept informed of the progress and outcome of the procedure. We strive for utmost transparency towards the whistleblower, but in certain cases we must also take into account the legally protected interests of third parties.

Duration of the procedure
apt makes every effort to process all incoming reports and complaints quickly and without culpable delay. At the same time, it is ensured that the person providing the information is given sufficient time to participate in the investigation of the facts. The duration of the investigation may vary depending on the size and complexity of the case.

Procedural Costs
The procedure described in these regulations may be used free of charge. Costs incurred by the whistleblower in connection with the use of the complaints procedure are not covered by apt, this also applies to travel costs or costs for legal advice.

Procedure

Submission of information or complaints
Authorized persons: Anyone can report.

Required information
To enable proper processing, reports should be formulated as specifically as possible, based on the following questions:

Who? What? How? When? Where?

Procedure after submission

Confirmation of receipt:
Receipt of the complaint will be acknowledged in writing or electronically within seven days, provided contact information is known.

Registration and forwarding:
The complaint is registered by apt as a case and forwarded to the relevant investigation unit.

Investigation of the complaint:
The investigation unit checks whether a sufficiently concrete initial suspicion exists.

Follow-up measures:
In case of suspicion, appropriate preventive and corrective measures are investigated.

Conclusion and evaluation:
The investigation results and measures are documented in a final internal report and the whistleblower is informed in writing of the completion of the procedure no later than after three months and seven days.

Your reports are crucial to prevent serious harm to our company, our partners and our employees. If you observe any (potential) possible wrongdoing or suspicion, please do not hesitate to contact us through our system.

Thank you for your trust and support.

Would you like a personal consultation?

Manon Gahmann

Director CSR & Compliance

Telefon: +49 2173 / 962 314 ethics@apt-alu-products.com