Whistle blowing Policy and Procedure

This guideline enables employees and other relevant stakeholders, to report every perceived act of inappropriateness, which is not based on conjecture or rumors, but on facts. The notifiable misconduct, which are concluded in this guideline, are: 

  • Every form of financial abuse or deficiencies like fraud, corruption, bribery, theft and deception
  • Violation of legal obligation, laws or guidelines
  • Actions which are against health or safety of the working environment
  • Every form of criminal activity
  • Inappropriate or unehtical behaviour, which undermines universal and ethical core principles
  • Behavior against values like integrity, respect, honesty and fairness
  • Other forms of violation against the code of behavior
  • Executedtransactions, which are not allowed to be published according to the regulations
  • Insider abuse
  • Behavior against the disclosure of interests  
  • Sexual or physical abuse of employees, customers, prospective employees, service providers or other relevant stakeholders

 The administrative board and the management are aware, that a resilient, internal system for employees and other relevant stakeholders, which reveals the misconduct of employees without reprisal, shows that employees are taking their responsibilities serious and helps as well to avoid negative publicity, which commonly occurs when disclosing to third parties.
Therefore the administrative board and the management strives for a culture of sincerity, accountability and integrity and does not tolerate molestation, victimization or discrimination of the whistle blower, premised, the disclosure is based on good will with the justified assumption, that the provided information is based on facts.

Generally defined in our guideline are values for employees.

This codex helps us to meet the standards, which we have set up for us as a company. Our methods of working serve to protect us and create an environment of fairness, integrity and respect which are the norm.

It requires courage to speak out against unethical behavior. Everyone who finds this courage shall know that we are behind her or him.

Internal & external process
Customers, employees and interested parties, who feel the necessity to report something, are provided with a clear and confidential process:

Try to report incidents as fast as possible, ideally at our delegated auditing company:

MWE Treuhand GmbH
Att. Mr. Marcel Weber
Gewerbestrasse 9
CH - 8132 Egg


Formal letter of revision:
MWE Treuhand Gmbh
Att. Mr. Marcel Weber
Gewerbestrasse 9
CH - 8132 Egg

Dedicated telephone number: 0041 44 533 81 80


Roles and responsibilities
Below are the roles and responsibilities of the central parties of the whistle blower process:


Whistle blower
Whistle blowers are expected to act with good will and renounce from false accusations, when reporting their concerns. They are expected to provide further information to support the investigation of the reported issue. 

The suspect is obliged to cooperate with the investigator during the evaluation period, including the provision of relevant information, documents or other material that the investigator requires. 

Leader of investigation
It is expected, that the leader of investigationtreats every affair confidential, contemporary and with high professionalism. She or he must be independent and unbiased to lead the investigation. The leader of revision is responsible to acknowledge every concern and to keep the whistle blower informed about the status of the investigation.

The leader of the internal audit provides the management with an annual report of every reported incidents and the outcome of the investigation. 

CEO and reviser
The CEO of the stock company provides the administration board with an annual review from the leader of revision about the reported deficiencies and acknowledges every hint, which has been submitted to the reviser.

Objectives of the guideline
Out of this guideline you will learn how to react when you ascertain misconduct. Misconduct includes every form of crime, contravention of law or deliberate violation of the code of behavior.