Dr. Olaf Christiansen
Senior Vice President, Corporate Legal Department – Integrity & Compliance
At Bertelsmann, employees, business partners and third parties always have the opportunity to ask for advice, discuss a concern about potential misconduct or provide suggestions for improving compliance procedures.
Retaliation against employees who raise concerns in good faith about suspected misconduct is prohibited (Please see Code of Conduct paragraph 2.1.2 [PDF-file, page 12] "Freedom to speak without fear of retaliation").
The following resources are available for employees as well as third parties:
Employees may contact a person in their immediate working environment to discuss questions regarding the Code of Conduct or to report violations; for instance: their supervisor, senior management of their company, the Human Resources, Legal, Finance or Audit departments, or, if applicable, their respective employee representatives.
A key responsibility of the Bertelsmann Integrity & Compliance Department is to support requests relating to the Code of Conduct and to ensure that reports of violations are investigated. Investigations are conducted with the greatest possible regard for confidentiality and in compliance with data protection requirements.
Employees or third parties may also report substantial violations of the Code of Conduct, specifically illegal business practices, using an Internet-based system. The system is available in multiple languages and allows for a confidential and specially encrypted, secure dialog with the Bertelsmann Integrity & Compliance Department.
Employees or third parties may also contact one of the external ombudspersons appointed by Bertelsmann. The ombudsperson’s role is to provide a neutral and independent channel for inquirers seeking confidential guidance in raising and resolving any suspected substantial violations against the Code of Conduct, especially illegal business practices. The ombudsperson treats all communication with those seeking assistance as confidential, and does not disclose details of the case, including the identity of the inquirer, unless given explicit permission to do so by the inquirer.
For toll-free phone numbers to reach the Ombudspersons, please refer to the Bertelsmann Code of Conduct [PDF-file, page 42] .
Employees can find more information on the Speak up channels in the Bertelsmann intranet.