Whistle-blowing management system in the HGK Group

Background:
The image of Häfen und Güterverkehr Köln AG and its subsidiaries and holding companies in the public arena is largely determined by the demeanour, actions and behaviour of its employees and any other person representing the Group. Adhering to statutory provisions and operational guidelines as well as fighting corruption are extremely important.

As part of introducing group-wide compliance within the City of Cologne Public Utilities Group, a whistle-blowing system involving an outside ombudsman has been established and the companies in the HGK Group participate in this too.

The whistle-blowing management system provides an orderly procedure for information about

• any infringements of statutory provisions in criminal law related to combatting corruption (bribery, accepting benefits, corruption, granting benefits),
• any crimes related to competition (price agreements, submission fraud),
• any infringements of antitrust law involving criminal punishment or fines, including crimes typically associated with them (e.g. fraud, embezzlement, forgery of documents, property offences).

The procedure also provides the possibility of providing information about infringements of

• the standards and goals from the internal guidelines on dealing with business partners,
• the internal rules to uphold antitrust law provisions,
• the guidelines for handling gifts/sponsoring.

The procedure seeks to protect the whistle-blower and the transparency and appropriateness of checking the information. This system is both geared towards employees in the companies in the HGK Group and external parties, particularly customers, contract partners, providers of services and competitors.

Ombudsman:
The ombudsman is a contact partner outside the City of Cologne Public Utilities Group. He has many years of experience in the appropriate legal fields.

He is available as a confidential contact partner for all the employees of the City of Cologne Public Utilities Group and therefore the HGK Group or anybody outside the Group.

The ombudsman accepts information about corruption and examines whether this should be followed up. He also helps to ensure that any misuse of the external information pathway does not occur or is recognised and prevented through personal discussions with whistle-blowers and on account of his experience.

Anonymity:
If whistle-blowers would like to remain anonymous, the ombudsman guarantees this anonymity.

Contact details:
The appointed ombudsman is the solicitor: