1. Purpose
Hanns R. Neumann Stiftung (HRNS) expects everyone who works for or with the organization to follow high ethical standards. The objectives of this Whistleblowing Policy are to encourage employees, partners, beneficiaries and other stakeholders as well as third parties to report concerns about unethical or illegal behavior, without fear of retaliation or punishment.
2. Scope
This policy applies to all employees, contractors, partners, consultants, interns, volunteers, and others engaged with HRNS.
It also applies to all subsidiaries and affiliates of HRNS. However, they may choose to use their own policies provided that they follow the rules in this policy as a minimum standard.
3. What is Whistleblowing?
Whistleblowing is the reporting of suspected misconduct, ethical violations, breach of company policies, illegal acts, or failure to comply with legal obligations. This may include, but is not limited to:
4. Reporting Procedure
Concerns should be reported as soon as possible through one of the following channels:
In addition, whistleblowers are free to contact external reporting offices at a government agency. The person reporting the violation is free to choose which office to report to. In cases where effective internal measures can be taken against the possible legal violation and there is no fear of reprisals, reporting to an internal reporting office is preferred.
5. Confidentiality and Anonymity
All reports will be treated confidentially. Whistleblowers may choose to remain anonymous, although this may limit the possibility of a full investigation.
For contacting the Compliance Officer anonymously, the report can be submitted through the HRNS website using the reporting form and leaving optional fields, i.e., name, email address, blank or using a trash mail account, e.g., trash-mail.com.
For contacting the external ombudsperson or the Compliance Officer anonymously through email or mail, you can request your identity to stay confidential while still keeping a line of communication open. The Compliance Officer and the external ombudsperson shall respect your wish for confidentiality.
6. Handling of Reported Concerns
Receipt of each reported concern will be acknowledged within five working days by the person to whom the report was addressed to, but only if the identity of the reporting person is disclosed or a return address is provided.
All reports will be promptly investigated; appropriate corrective action will be taken if warranted by the investigation.
7. Protection Against Retaliation
HRNS prohibits retaliation against anyone who raises a concern in good faith. Any form of retaliation will be treated as a serious disciplinary offense and can lead to termination of employment or cooperation.
8. Investigation
All reported concerns will be promptly, thoroughly and impartially investigated by the person to whom the report was addressed (Compliance Officer, external ombudsperson or Managing Directors). The whistleblower may be asked for further information during the investigation if contact details were provided.
If a report refers to a suspected misconduct/breach of rules etc. of the Compliance Officer, the responsibility for initiating and overseeing the investigation shall rest directly with the Managing Directors or the designated external ombudsperson. In such cases, the Compliance Officer shall have no role in the investigation process. The Management may engage independent external parties to ensure a fair and impartial investigation.
9. Record Keeping
HRNS will securely keep all reports and investigations for ten years.
10. Policy Review
This policy will be reviewed regularly and updated as necessary to remain effective and in line with legal requirements.
11. Contact
Compliance Officer: Marion Schenk
Email: complianceoffice@hrnstiftung.org
Phone: +49-40-808112 419
Address: Am Sandtorpark 4, 20457 Hamburg, Germany
Hanns R. Neumann Stiftung, July 2025