Fuchs Gruppe is committed to effectively complying with the Compliance System and Reporting Channel. Compliance means observing legislation, the law and Fuchs Gruppe's internal rules, and creating structures to ensure that Fuchs Gruppe, its management and all its employees can behave lawfully. The ISO 27001 certified compliance provider and whistleblowing system www.safewhistle.info They are part of the Fuchs Gruppe compliance system and compliance culture.

Why did Fuchs Gruppe appoint a compliance provider?

Your information helps us to neutralize violations of applicable law or internal Fuchs Gruppe guidelines at an early stage and to prevent harm to our employees, business partners, third parties and also to Fuchs Gruppe. For this reason, Fuchs Gruppe has appointed a Compliance Ombudsman, Mr Lutz Kühne, to whom employees, business partners and third parties can turn as an external, independent and impartial contact person if they have any indication that violations of applicable law or internal regulations of Fuchs Gruppe occurred.

Contact details are as follows:
Rödl & Partner BR
Lutz Kühne
Rödl & Partner Consultores Ltda.
Rua Verbo Divino 1488, 3rd floor room 3a
04719-904 São Paulo – SP
Telephone: +55 11 504 6060 Ext 1290

lutz.kuehne@roeldl.com
tropoc.hotline@roedl.com
www.roedl.de/brasilien

Which whistleblowers are protected ?

Any whistleblower acting in good faith has the right to provide information. Whistleblowers who act in good faith fall within the scope of protection of these Internal Regulations. Good faith is considered to exist if the complainant assumes, at the time of reporting, that the information provided is true.

What crimes are relevant?

All violations of applicable law are relevant, in particular in the area of white-collar crimes or violations of obligations relating to human and environmental rights, in particular those under Sections 2, Paragraph. 2 and 3 of the Supply Chain Due Diligence Law. However, violations of Fuchs Gruppe's internal regulations can also be reported.

On the other hand, if you have any questions about your order, want to complain about a product, are dissatisfied with our performance or service, or have any other questions, please use our usualoptions contact information .

How can I provide information?

Please report to the Compliance Ombudsman

• in which company or part of a company
• what happened
• quando
• where
• Please report to the Compliance Ombudsman

The Compliance Provider is also interested in knowing which other people – who may not be involved in the specific processes – are aware of this and whether there are documents (e.g. emails, photos) relating to this.

Before providing information, please check carefully that the statements you make are accurate in relation to their content. In particular, you must not provide any information that you know to be false.

Please also let your Compliance Provider know how they can contact you if they have any questions.

What costs are associated with providing information?

There are no costs to the whistleblower associated with providing the information.

What should I do if I am not sure whether a relevant offense has been committed?

Se não tiver certeza, use frases como “ Eu acredito …” ou “ Eu acho que é possível … ”

Caso haja dúvidas sobre a apresentação, avaliação e/ou procedimento, você pode conversar com o Provedor de Compliance sobre o caso antecipadamente – mesmo que de forma anônima – e gratuitamente.

Devo revelar minha identidade quando forneço informações?

Whistleblowers remain anonymous if they wish. Whistleblowers can agree with the Compliance Provider how they can be contacted if they have any queries, if the whistleblower wishes to remain anonymous. No false information may be communicated, even in the case of an anonymous report. Whistleblowers can ask lawyer Dr. Dilling not to reveal to Fuchs Gruppe an identity he knows.

How is the whistleblower’s identity protected?

Whistleblowers can request the Compliance Ombudsman to protect their identity and not to disclose to Fuchs Gruppe their identity or any other information that would allow conclusions to be drawn about their identity.

Mr. Lutz Kühne is bound by professional secrecy and cannot disclose the identity of a whistleblower known to him to third parties without incurring criminal liability. Mr. Lutz Kühne has taken appropriate technical and organizational measures to protect the information he receives in such a way that third parties cannot access it.

The information passed on by Mr. Lutz Kühne to Fuchs Gruppe is also treated confidentially and protected there. The people at Fuchs Gruppe responsible for processing information are required by law to maintain confidentiality insofar as human rights violations and breaches of duties related to the environment are reported. They are also contractually obliged to treat reports received and, in particular, the identity of the person providing the information as confidential. Furthermore, the people responsible for processing reports at Fuchs Gruppe are independent and are not subject to instructions. In particular, they receive no instructions from either the company management or the works council regarding the content or the procedure for conducting a procedure, for example with regard to the type and scope of the procedure or its termination. Fuchs Gruppe organizationally guarantees that only those people responsible for processing the reports can access the reports and the documents presented with them.

Without the consent of the person providing the information, the identity of the person providing the information and the circumstances allowing conclusions to be drawn about the identity of the person providing the information cannot be transmitted, even during internal processing of information within the Group. Fuchs.

Is the protection of identity confidentiality absolute?

No, it's not.

First, Section 9, Para. Article 2 of the Whistleblower Protection Law provides exceptions to confidentiality that, for example, allow the identity of a whistleblower to be transmitted to a law enforcement authority if the latter requests it. Section 9, Para. 2 of the Whistleblower Protection Law is expressly referred to.

Secondly, the protection of confidentiality is benefited only by people who act in good faith, that is, who do not transmit false information intentionally or through gross negligence. A whistleblower who, intentionally or through gross negligence, transmits false information must expect that his or her identity will become known through a request for information from the data subject in accordance with Article 15 Para. 1 GDPR, and that the data subject of the data will claim compensation.

Finally, neither Mr. Lutz Kühne nor Fuchs Gruppe are protected from seizure, i.e. in the event of an official investigation, authorities may seize documents that reveal the identity of the person providing the information.

Whistleblowers who fear their identity becoming known are therefore advised to file a report anonymously. Even in the case of an anonymous report, no false information may be transmitted.

Here again, if you are not sure, use phrases like “ I believe …”, “  I think it's possible …” or “ It could be that  …”

Do I need to fear professional disadvantages if I give information?

No, professional discrimination and reprisals against whistleblowers are strictly prohibited. The Fuchs Gruppe Supplier Code of Conduct also contains regulations that prohibit Fuchs Gruppe suppliers from suffering reprisals if whistleblowers provide information. This also applies to threats and attempts to impose reprisals. Retaliatory measures based on reports will not be tolerated. Whistleblowers are encouraged to report the matter if they are subjected to any retaliation or reprisal by Fuchs Gruppe employees or Fuchs Gruppe suppliers for providing information in good faith. Fuchs Gruppe will respond to these employees or suppliers appropriately (e.g. issuing a warning, organizing a workshop, demanding compensation).

As part of the reporting procedure and also at the end of the reporting procedure, the Compliance Ombudsman will ask whistleblowers whether they have been subjected to reprisals by Fuchs Gruppe employees or Fuchs Gruppe suppliers as a result of the information provided.

Even after the process is complete, whistleblowers can report to the Compliance Ombudsman if they are subject to reprisals by Fuchs Gruppe employees or Fuchs Gruppe suppliers as a result of the information provided.

What is the position of the Compliance Ombudsman?

The Compliance Ombudsman is not a dispute arbitration body. The client relationship exists only between the company and the Compliance Provider. However, the Compliance Provider acts impartially and is not bound by the instructions of Fuchs Gruppe, the Compliance Provider is obliged by law to maintain confidentiality.

What happens to the information?

The Compliance Provider will inform you within 24 hours of receipt of the information. The Compliance Ombudsman clarifies with the complainant the facts of the case and what expectations the complainant has regarding possible preventive or corrective measures, and checks whether the information falls within the scope of the complaints procedure, namely whether there may be a violation of rights humans. or environmentally related breach of duty within the meaning of Section 2 Para. 2 and 3 of the German Supply Chain Duty of Care Act (Lieferkettensorgfaltspflichtengesetz). If, in the opinion of the Compliance Ombudsman, there is no material breach, he or she will provide reasons for this to the complainant. On the other hand, if a material breach appears possible, the Compliance Ombudsperson processes the information and passes it on confidentially to the Fuchs Gruppe Compliance Officer. The Fuchs Gruppe Compliance Officer decides, together with company management, if necessary, how to handle this information. If there are sufficiently concrete reasons to suspect legal or political violations, these are investigated internally in order to clarify and remedy possible misconduct. As a general rule, this is also done confidentially and discreetly, in order to protect the interests of the whistleblower and those affected by the reports. The reporter will receive feedback from the Compliance Provider no later than three months after the report was made regarding whether the reported violation was identified. If this is the case, the violation will be remedied. The whistleblower's expectations are taken into account. If, in his opinion, the corrective measures taken are not sufficient, the whistleblower is encouraged to report this fact.

How can I contact the Compliance Provider?

You can contact the Compliance Provider in any conceivable way (telephone, email, fax, post or via the reporting system www.safewhistle.info ). The Compliance Ombudsman is also available for face-to-face meetings with whistleblowers, including via video and audio transmission, upon request. If you wish to communicate encrypted, you can also use Signal and Threema messaging services to contact the Compliance Provider. You can also send encrypted emails to the Compliance Provider via Protonmail to the following address:

Rödl & Partner BR
Lutz Kühne
Rödl & Partner Consultores Ltda.
Rua Verbo Divino 1488, 3° andar sala 3ª
04719-904 São Paulo – SP
Telephone: +55 11 504 6060 Ext 1290
lutz.kuehne@roeldl.com
tropoc.hotline@roedl.com
www.roedl.de/brasilien

Whistleblowers can report infractionsina language of their choice , through the reporting portal https://roedl.de/brasilien , through the services of messages stored there, by email or by post.

Whistleblowers may also request the Compliance Ombudsman to arrange for an interpreter who is under a special obligation of confidentiality to participate in a personal meeting with the Compliance Ombudsman at Fuchs Gruppe's expense and who can translate it into the whistleblower's national language.

At the special request of the whistleblower, Fuchs Gruppe will provide a compliance provider as a contact person, at its own expense, in individual cases.