Speak-up channels: Raise concerns and report violations
At Bertelsmann, employees, business partners and third parties always have the opportunity to ask for advice or discuss a concern about potential misconduct.
Retaliation against employees who raise concerns in good faith about suspected misconduct is prohibited (Please see Code of Conduct paragraph 2.1.2 "Freedom to speak up") .
Concerns can be raised in the local working environment, or through resources provided on Bertelsmann corporate level (“speak-up channels”), which are available to employees as well as third parties. The Bertelsmann Integrity & Compliance is responsible for managing the speak-up channels and coordinates the handling of compliance concerns. When investigating reports of misconduct, the rights of everyone involved are protected and decisions on disciplinary measures are made fairly, appropriately, confidentially, and transparently. Further information on how reports are handled can be found in the “Speak-up Guide” .
1. Contacts in your local working environment
You can contact a person in your local working environment to discuss questions regarding the Code of Conduct or to report violations of the Code of Conduct or Compliance guidelines for instance: Your supervisor, the senior management of your company, your local Compliance Officer, the Human Resources, Legal, Finance or Audit departments, or, if applicable, your employee representatives. Employees can find a list of people to contact for each Bertelsmann subsidiary on the Bertelsmann Intranet.
2. Contacts in the Bertelsmann Corporate Center
If you are uncomfortable addressing your concern locally, or if doing so has been ineffective, you may also contact the appropriate department at the Bertelsmann Corporate Center, in particular the Integrity & Compliance department. Your concern will be handled with the greatest possible regard for confidentiality and in compliance with all applicable data protection requirements. All reports of suspected compliance violations will be investigated.
E-mail: Send email
3. Speakup system
You may also report violations against the Code of Conduct, particularly illegal business practices, using a Speakup system. The system is available in multiple languages and accessible by phone or internet. It allows for a confidential dialogue with the Bertelsmann Integrity & Compliance department, secured by special encryption and anonymous if desired.
You may also contact an external ombudsperson appointed by Bertelsmann. The ombudsperson’s role is to provide a neutral and independent contact person for inquirers seeking guidance and support in raising and resolving any suspected substantial violations against the Code of Conduct. The ombudsperson holds all communications with those seeking assistance in strict confidence, and does not disclose any content of the communications, or the identity of the inquirer, unless given explicit permission to do so by the inquirer.
Ombudsperson for Europe, Africa, Asia and Australia (located in Germany)
Tel. +49 (0) 32-211 11 23 39
Toll-free: 0800-664 7879 (from Germany only)
Ombudsperson for North and South America(located in the USA)
Tel. +1 646-981-0753
Toll-free: 877-278-0303 (from USA only)
5. External channels
In the event that individuals still do not wish to entrust their compliance concerns to one of Bertelsmann’s points of contact, they may alternatively turn to the relevant external reporting bodies. External reporting channels are increasingly being established, especially for member states of the European Union. An overview of existing external reporting channels is provided here and will be continually updated.