Strict compliance with legal requirements is an indispensable component of MVV’s corporate culture. Particularly in especially sensitive areas, such as anticorruption measures / integrity of business operations, cartel law and adherence to labour and environmental standards, any misconduct even on the part of one single individual can significantly harm the company.
One key element of our Compliance Management System (CMS) is the Whistleblower Hotline (WBHL). This enables employees and third parties to report any potentially severe misconduct with absolute anonymity to the external confidence lawyer Dr. Björn Kruse (Tel. 069/77019678, E-Mail: kruse@). Every tip-off received is followed up and the matter reported is investigated. feigen-graf.de
Tasks of the confidence lawyer
MVV actively aims to prevent any kind of criminal action or gross infringements of legal requirements. In particular, it operates a zero tolerance policy towards bribery and all other forms of corruption. The appointment of an external confidence lawyer is one aspect of the integrative Compliance Management System (CMS) in place at the company.
As the confidence lawyer for MVV, Dr. Kruse acts as the contact partner for internal and external informants, particularly with regard to cases of suspected corruption and other criminal actions or gross infringements of legal requirements. The confidence lawyer is bound by the oath of professional secrecy, as are all of the employees at the law firm. The confidence lawyer only passes on the information received to MVV if the informant has explicitly consented to such step.
The confidence lawyer is also available to MVV’s employees to answer questions concerning the correct conduct in accordance with the relevant regulations for specific incidents or cases of suspected misconduct when the employees wish such enquiries to be dealt with confidentially. If desired, informants and employees who approach the confidence lawyer with tip-offs or questions may remain anonymous.
A special telephone number has been installed for those individuals wishing to contact Dr. Kruse as MVV’s confidence lawyer to inform him about any suspected cases of corruption or infringements of legal requirements. An answerphone is available to record messages outside the law firm’s normal office hours.
As a general rule, the process begins with the informant contacting the lawyer by telephone or mail. This initial contact may already serve to clarify the potential relevance of any tip-off. In suitable cases, the initial contact by telephone will be followed by a one-to-one conversation between the informant and the confidence lawyer in which the matter in hand is discussed as precisely as possible.
Only if the informants provide their explicit consent will the confidence lawyer then pass on the information to the company, and then only to the individual appointed by the Executive Board for this purpose. If desired by the informants, the name will not be mentioned.
Taking up contact with the confidence lawyer does not involve any risks for informants who are still undecided as to what to do. Even after talking to the confidence lawyer, they may still request the confidence lawyer not to mention the matter discussed.
The tasks performed by the confidence lawyer are limited to accepting tip-offs relating to corruption, criminal actions or offences of material significance. The confidence lawyer cannot act as a general complaints office, but only as a specific channel for obtaining information about suspected cases of corruption or other infringements of legal requirements.
The confidence lawyer is not able to accept general customer complaints.
The confidence lawyer acts on behalf of MVV. He may never provide an informant with legal advice that runs contrary to the company’s interests. He is nevertheless commissioned by the company to provide informants with information about company-internal measures initiated on the basis of the information provided.