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Compliance – Drooms Code of Conduct/Whistleblower System

Drooms Code of Conduct

The Drooms Code of Conduct is used by the Drooms Group to set out its core values and ethical standards, including integrity and compliance with the law. Our corporate culture is guided by these core values.

Our Code of Conduct provides a clear framework for our decisions and actions. All Drooms staff are required to adhere to the principles set out in the Code of Conduct, ensuring that the business remains accountable and takes responsibility for the role it plays in society.

Download the Drooms Code of Conduct here.

Compliance reporting

In addition to the Drooms Code of Conduct, our compliance reporting process is a vital component of our compliance management system. Unethical, illegal and irresponsible actions harm the Drooms Group and its stakeholders, i.e. customers, shareholders, service providers, partners and employees. As such, whistleblowers can make a significant contribution in combating and preventing illegal and problematic activity.

We have provided several ways for our employees, business partners, customers and service providers to approach us should they wish to report potential compliance violations involving the Drooms Group.

In addition to the option for our employees to report incidents directly to their immediate supervisors or to the Drooms Legal or Infosec teams, Drooms also operates an electronic whistleblower system, which can be used by both employees and other stakeholders. This platform facilitates protected communication between whistleblowers and the unit responsible for compliance reporting at Drooms. The system allows whistleblowers to decide for themselves whether they want to provide their name or remain anonymous.

The electronic whistleblower system

Integrity Plattform

FAQs

For whom was the whistleblower system designed?

Any employee who gains knowledge of illegal or problematic activity should use our whistleblower system if they feel they are unable to discuss the issue with their supervisor.

However, any other Drooms stakeholder, i.e. customers, shareholders, service providers, partners, etc., who gains knowledge of illegal or problematic activity can also use the whistleblower system to report information.

Failing to act and burying our head in the sand will only increase the damage caused and the frustration that comes with making a mistake.

We want to assure potential whistleblowers that acting with integrity will never work to their disadvantage.

However, users should be advised that the system is not intended to be used to knowingly provide false or defamatory remarks or information.

What kinds of violations should be reported using the whistleblower system?

Whistleblowers can use the hotline to report illegal activity or failures to act involving the Drooms Group, including information on violations relating to:

  • fraud and property-related crime (such as theft, bribery and other monetary rewards, fraud, or embezzlement)
  • the protection of privacy and personal data
  • a breach of confidentiality or disclosure of trade secrets
  • conflicts of interest
  • infringement of antitrust law and/or competition law, copyright infringement or infringement of trademark rights
  • violations of money laundering regulations; insider trading
  • accounting manipulation
  • environmental protection
  • health, occupational safety and operational safety
  • bullying and discrimination in the workplace
  • breaches of network and information systems security

 

Please note: Our whistleblower system should not be used to submit queries or complaints to our Customer Support Services or to our Technical Support Service.

If you wish to get in touch with our support teams, please contact:

Technical Support (reporting errors and problems):

 

Please note that our whistleblower system does not function on an emergency basis.

How should information be submitted?

Information can be submitted through our electronic whistleblower system or by calling our whistleblower hotline.

Whistleblowers can access the whistleblower hotline by calling +49 69 9999 8839. The hotline is open from 9am to 5pm, Monday to Friday.

We recommend submitting reports via our electronic whistleblower system. Using the electronic whistleblower system on our website does not permit us to track you. Reports can be submitted anonymously and without trace.

You can also access our electronic whistleblower system by scanning the following QR code:

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Can information be submitted anonymously? What happens to any personal data provided by whistleblowers?

Yes, information can be submitted anonymously via our electronic whistleblower system if the whistleblower submits the report without providing any personal data. In this case, messages are essentially untraceable. If a whistleblower prefers, they can maintain their anonymity throughout the process while still communicating with the unit in charge of compliance reporting at Drooms.

If a whistleblower voluntarily provides personal data when reporting, any queries should be submitted to the data controller, which is Drooms GmbH, Eschersheimer Landstr. 6, 60322 Frankfurt am Main, Germany. You can reach Drooms GmbH’s data protection officer at dataprotection@drooms.com. Drooms GmbH uses an electronic whistleblower system operated by LegalTegrity GmbH, Frankfurt, Germany. Drooms GmbH has concluded a data processing agreement with LegalTegrity GmbH pursuant to Article 28 of the GDPR. Data is stored and processed in Germany. Data will only be processed for the purpose of investigating the incident reported and to facilitate contact with the whistleblower should any queries arise. The length of time data is stored varies on a case-by-case basis, and the retention period is based on statutory periods of limitation under civil and criminal law. Data will only be disclosed to the Drooms Group, and only to those with authorised access and for whom it is necessary to view the data in question in order to investigate the incident. Whistleblowers have the right of access and the right to rectification, erasure, or restriction to processing, the right to data portability, the right to object to their personal data being processed, and the right to lodge a complaint with the competent data protection authority.

What happens after a whistleblower has submitted a report?

Information reported using our whistleblower system is received by the unit in charge of compliance reporting – the Legal and Infosec teams at Drooms GmbH – where it is reviewed accordingly. Whistleblowers will receive confirmation that their report has been received and will be provided with updates on the progress/outcome of the investigation within the prescribed legal deadlines.

Even if a whistleblower remains anonymous and prefers not to provide contact information, they can use the electronic whistleblower system to communicate with us, ask any additional questions and receive information about the progress of the investigation. When reporting, whistleblowers receive an individual PIN they can use to anonymously access the electronic whistleblower system at any point and view information about the incident they reported and our response.

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