Report a Suspected Misconduct

If you as an external person or VAT employee observe any violation of our code of conduct, you have the possibility to turn to the following contact:

As an employee in addition to

  • Your local manager or local management, or
  • Your local HR department.
  • Legal and Compliance Department
  • Internal Audit

How to Report Your Concern?

In order to report misconduct, please refer to the contact information provided above.

Although English or German are the languages that are preferably used, you are free to report in any other language.

The concerns can of course be raised anonymously. However, we ask you to indicate a possibility to contact you, such as an 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 or other serious breach of the VAT Code of Conduct;
  • gravely incorrect management or employee application of the VAT passions 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 suspected misconduct, the information will be evaluated by the responsible VAT representative (usually by the Compliance Department) in order to find out whether:

  • the reported behavior occurred and if it constitutes a misconduct;
  • a full investigation of the issue is appropriate;

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 and 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. For reasons of data protection and keeping business secrets, you may not be informed about the results of the investigation and measures taken for avoidance of further occurrence. 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 neither have to fear any kind of discrimination nor retaliation. If you think, however, that you have been a victim to discrimination or retaliation because of your collaboration concerning misconduct, we encourage you to report this to the Compliance Contact form. All matters of this kind will be treated strictly confidential.