Linova Software GmbH Internal Reporting Office

Linova values constructive dialogue and encourages feedback and discussion. Leadership and management are always grateful for feedback of any kind that improves collaboration or highlights issues. To this end, we rely on open and direct communication among one another.

In addition, employees may at any time, as needed or when appropriate, submit reports—either anonymously or by providing their identity—regarding misconduct or potential legal violations at Linova and in Linova’s business activities. To this end, Linova has established an internal reporting office in accordance with legal requirements. This internal reporting office is operated by an external law firm. Every report is therefore subject to attorney-client privilege, thereby ensuring the protection of all data and information.

Further information on the Whistleblower Protection Act and the internal reporting office, on possible external reporting channels in addition to the internal reporting office, as well as on procedures for submitting reports to institutions, bodies, or other agencies of the European Union, can be found on our internal reporting office’s website: https://anwaltliche-meldestelle.de.

When a report is submitted through the channels mentioned above, the following is guaranteed:

1. The whistleblower will receive confirmation of receipt of a report no later than seven days after the report is received.
2. A review will be conducted to determine whether the reported violation falls within the scope of application under Section 2 of the Whistleblower Protection Act (HinSchG).
3. The reporting office will maintain contact with the whistleblower and, if necessary, coordinate the collection of any additional required information.
4. The whistleblower will receive feedback within the timeframe specified in Section 17(2) of the HinSchG (provided there are no legal reasons preventing this). The feedback will include a description of the follow-up measures planned and already taken by Linova, as well as the reasons for these measures.
5. With regard to appropriate follow-up measures under Section 18 of the HinSchG, the affected individuals and/or work units at Linova will be contacted, or the reporting office will refer the matter to Linova for further investigation (Section 18(4)(a) of the HinSchG), provided that it cannot itself initiate or carry out corresponding measures pursuant to § 18 HinSchG.

Rights and Obligations of Whistleblowers

Whistleblower Rights: A whistleblower has the right to protection from any form of retaliation if he or she reports misconduct in good faith. This means that he or she does not have to fear negative consequences such as termination, discrimination, or harassment. We value and respect their contribution to uncovering wrongdoing.

Reporting Obligations: We encourage whistleblowers to report violations of applicable laws, internal policies, or our company’s ethical principles. This may include, for example, fraud, corruption, discrimination, environmental offenses, or other forms of misconduct. It is important that they act honestly and responsibly when reporting misconduct.

If the whistleblower feels that his or her report is not being handled appropriately internally, or if he or she prefers to use an external channel, he or she has the right to contact external reporting bodies such as the relevant authorities or ombudspersons, such as the Federal Office of Justice (BfJ). The BfJ serves as an external reporting office itself and also refers reporters to other competent reporting offices for specific matters.

Confidentiality and Data Protection

Protection of the Whistleblower’s Identity: The confidentiality of the whistleblower’s identity is our top priority. All reports are treated confidentially, and we take comprehensive measures to ensure that the whistleblower’s identity is not disclosed without authorization. Upon request, the whistleblower may also remain anonymous.

Handling of Personal Data: The personal data of the whistleblower will be processed in accordance with applicable data protection regulations, in particular the GDPR. We collect only the data necessary to process the report and ensure that it is handled securely and confidentially. Data will be disclosed to third parties only if required by law or if the whistleblower has expressly consented.

Complaint Procedures

Internal complaint procedures: If the whistleblower is dissatisfied with how our whistleblower system operates or believes that their report was not handled properly, they may file a complaint internally with our Compliance Office. The Compliance Office will carefully review the complaint and provide feedback to the whistleblower.

External Complaint Channels: If the whistleblower disagrees with the internal handling of the matter or does not feel safe, he or she has the right to file a complaint with external bodies, such as a supervisory authority. The Federal Office of Justice serves as a supervisory authority itself and also refers whistleblowers to the appropriate supervisory authorities for specific matters.

Sanctions and Measures for Violations

Consequences: Intentionally submitting false or malicious reports constitutes an abuse of the whistleblower system and may result in legal and disciplinary consequences. We ask whistleblowers to use the system responsibly.

Protection against retaliation: We guarantee that whistleblowers acting in good faith will under no circumstances be sanctioned or disadvantaged. Their courage in reporting misconduct helps make Linova safer and more responsible.