Report a suspected misconduct to the Compliance Hotline

In case of any misconduct, employees and external stakeholders (e.g. contract partners) of VAT receive the opportunity to report the suspected misconduct in a secure and confidential way. The VAT Head of Legal and Compliance is the owner of the Compliance Hotline and hence also monitors it.

We draw your attention to the fact that as an employee of VAT, you have the possibility to turn to the following parties in order to raise your concern:

  1. Your local manager or local management, or
  2. Head of Legal and Compliance (Marcel Körting), or
  3. Head of Internal Audit (Markus Jaeger), or
  4. Your local HR department.

If these possibilities are not suitable for you, please follow the instructions below.

Marcel Körting

Your contact person

Marcel Körting

Head of Legal & Compliance
+41 81 772 45 44

Contact

Markus Jäger

Your contact person

Markus Jäger

Head of Controlling & Treasury
+41 81 772 41 06

Contact

How to report your concern

In order to report misconduct, there is the Compliance Hotline available: Compliance Hotline Form

Although English and German are the languages that are preferably used, you are free to report in any other language and we will translate your report.

The concerns can of course be raised anonymously. However, we ask you to indicate a possibility to contact you, such as your E-mail or phone number, in case of any questions.

When to report a concern: If you observe

  • any matter that constitutes a legal risk or a risk to VAT, such as regarding Compliance, Export Control, Business Ethics, Accounting issues and Fraud as well as VAT values;
  • gravely incorrect management or employee application of the VAT values in management practices, business conduct and behavior, also regarding inappropriate treatment of employees by parties such as the direct manager or the line organization;
  • theft and embezzlement of VAT assets and funds and hence financial fraud, vendor fraud, acceptance of kickbacks, manipulation of accountancy, breaches in internal accounting controls and issues of auditing;
  • if members of VAT or third parties acting in the name of VAT give donations or gifts and entertainment which is unethical to business partners or public officials, as well as misconduct of Business Ethics, such as conflict of interests, corruption and within regarding payment of bribery or facilitation payments;
  • serious violations regarding Antitrust or Fair Trading, Espionage or Sabotage and violations of information security.

What happens with your report?

When you report about a probable misconduct, the information will be evaluated by the responsible VAT representative (usually by the VAT Head of Legal and Compliance) in order to find out whether:

  • the reported behavior occurred and if it constituted misconduct as a consequence;
  • a full investigation of the issue is inappropriate because credibility, materiality and/or verifiability is not given or not to a sufficient degree and/or;
  • there is a solution which is more appropriate and less formal or the topic forms part of the responsibility of another party.

As soon as the evaluation has been carried out successfully, the accusation will be investigated.

In case of a confirmed misconduct, possible sanctions and/or corrective actions will be considered, discussed, agreed and implemented by and between the assigned investigator, Head of Legal and Compliance, HR, Head of Internal Audit and management. The results will be documented in an appropriate way.

In the course of the preliminary evaluation and/or investigation you may be contacted to provide further details. The result of the investigation will be conveyed to you but only if you have provided your contact details.

Suspected compliance misconduct and the results of investigations will form part of management and audit reports to VAT Management, VAT’s Audit Committee and the Board of Directors on a regular basis.

Anonymity and Anti-Retaliation

Important: Persons who have reported misconduct or taken part in investigations in good faith do not have to fear any kind of discriminations nor retaliation. Such behavior will not be tolerated by VAT. If you think, however, that you have been victim to discrimination or retaliation because of your collaboration concerning misconduct, we encourage you to report this to the Compliance Hotline as quickly as possible. All matters of this kind will be treated strictly confidential.

© 2018 VAT Group AG | Switzerland
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