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") . When investigating reports of misconduct, the rights of everyone involved are protected and decisions on disciplinary measures are made fairly, appropriately, confidentially, and transparently.
The following resources are available for employees as well as third parties:
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 or Compliance Manager, the Human Resources, Legal, Finance or Audit departments, or, if applicable, your employee representatives. You 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.
3. Speakup system
You may also report substantial violations against the Code of Conduct, particularly illegal business practices, using a Speak-Up 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)
Dr. Olaf Christiansen
Senior Vice President, Corporate Legal Department – Integrity & Compliance