• Whistleblower Hint
  • Whistleblower protection policy

    • Guideline of ITOCHU Deutschland GmbH on the use of its whistleblowing system

    Are you aware of incidents within ITOCHU Deutschland GmbH where you have doubts as to whether they are in accordance with legal requirements or internal regulations?
    Then please let us know! We are counting on your support.
    This guideline is intended to explain how you can report compliance violations.

    1. Why is information important?
      • Compliance with laws and internal regulations is a top priority for ITOCHU Deutschland. We therefore want to be informed about unlawful behaviour in our company at an early stage so that we can clarify and remedy such behaviour. We encourage everyone - whether employees, former colleagues, customers, suppliers or third parties - to inform us of any legal violations. This information can help us to counteract violations at an early stage and minimise the damage to our company, our employees and our business partners.
      • This guideline is intended to ensure that information on violations is received, processed, stored, forwarded and archived in accordance with the Whistleblower Protection Act and other regulations (including Data Privacy Policy), with the necessary confidentiality.
    2. What can be reported? 
      • Violations of ITOCHU's internal regulations and guidelines, as well as violations of laws and other legal provisions, in particular the offences listed in Sec. 2 of the German Whistleblower Protection Act.
      • Only reports that are based on valid reasons may be submitted. ITOCHU Deutschland must receive verifiable and serious information about a violation that leads the whistleblower to believe that the reported facts are true and that he is therefore in good faith that the reported facts are correct.
      • The reporting channels are not available for general complaints or for product and warranty enquiries.
      • A whistleblower may be liable to prosecution if, against their better judgement, they make untrue statements about other persons.
    3. Who can provide information?
      • Anyone can provide information, regardless of whether they are a current or former employee, business partner or third party.
    4. How can information be submitted?
      Information can be submitted via the following reporting channels:
    5. Who is responsible for the whistleblower system?
      The central unit responsible for managing the whistleblower system for ITOCHU Deutschland is the ITOCHU Europe Compliance Team in London, United Kingdom. The persons entrusted with the management of the whistleblower system guarantee impartiality, are independent, not bound by instructions and are obliged to maintain confidentiality. They receive necessary training from time to time to ensure proper implementation of the requirements of the German Whistleblower Protection Act by ITOCHU Deutschland.
    6. What happens after information has been submitted?
      • The message is forwarded internally, securely and directly to the reporting office (ITOCHU Compliance Team).
      • Receipt of the report will be confirmed within seven days.
      • The reporting office will examine the information carefully and ask the informing person for further information if necessary.
      • The reporting office is independent of instructions and treats the report strictly confidentially and without any bias, both with regard to the identity of the whistleblower and the incident itself.
      • The reporting office takes follow-up measures:
        • The ITOCHU Compliance Team follows up every indication of compliance violations through internal investigations based on transparent and clearly defined processes.
        • Those affected are addressed. However, only people who are actually needed are included in the investigation and only to the extent necessary ("Need-to-know" principle).
        • If further investigations are necessary, the reporting office will forward the case to an appropriate department at ITOCHU or to a competent authority.
           
      • Reports are always treated with high priority. The processing time depends on the scope and complexity of the reported matter, which is why it can take several months. The whistleblower will receive feedback within three months of confirmation of receipt of the report. The feedback will include any planned follow-up measures as well as those already taken and the reasons for these.
      • If a violation of applicable law or internal regulations is confirmed, it is remedied immediately and the necessary measures are taken to prevent future violations of this kind (e.g. implementation of process improvements or taking personnel measures).
    7. You are protected!
      • All information, including references to the person providing the information, will be treated confidentially.
      • Whistleblowers need not fear retaliation for making a report if they do so in good faith. We prohibit and do not tolerate any form of retaliation (e.g., adverse treatment, disciplinary action, threats, intimidation) for reporting a violation or otherwise cooperating in the investigation of a violation.
      • The reporting of knowingly false information ("malicious reporting") itself is an offence. In such a case, appropriate action may be taken against the informing person.
      • Nobody has to expect the consequences of an investigation until they have had the opportunity to comment on the allegations.
    8. Confidentiality and data protection
      All information, regardless of its truthfulness, is likely to damage the reputation of the person concerned, the whistleblower and/or third parties as well as the business. We will therefore treat them with particular confidentiality over and above the obligations arising from data protection requirements.