SpeakUp compliance reporting system

SpeakUp compliance reporting system

On December 12th, 2016 Group Compliance Incident Reporting & Case Management Policy (the “Policy”) was released. The purpose of the Policy to allow reporting of any violation (or suspected violation) of laws, regulations and rules that apply to the Company (as defined herein below), as well as to ensure effective, timely and transparent processing of such violations in compliance with the Heidelberg Materials Code of Business Conduct and the Compliance management System of Heidelberg Materials Group.                                                                                                                  

This Policy applies to all employees, managers, directors, Supervisory and Managing Board members, third business partners (e.g. intermediaries, consultants, suppliers, customers, contractors) or other persons dealing with Heidelberg Materials Devnya JSC and its subsidiaries Heidelberg Materials Vulkan JSC, Heidelberg Materials Lyulyaka EAD and Heidelberg Materials Digital Hub Varna EAD (collectively referred to as the “Company”).

Incident means facts or behaviors non-compliant with laws and regulations, internal rules, policies or programs, Group Corporate Governance principles when committed by Company’s employees, managers, directors, Supervisory and Managing Board members, or other employees of the Company

Incidents include:
- Accounting / audit-related matters (deliberate errors, unethical or false statement of accounting and auditing reporting);
- Bribery and kickbacks;
- Child abuse or neglect;
- Conflict of interest;
- Compliance and / regulation violation (violations of or failure to comply with a rule, regulation, law, operating procedure, practice of any aspect of the activity of the company including antitrust/competition law violation);
- Discrimination;
- Embezzlement;
- Employees relation (any material issues related to the way employees work with each other, their superior/managers, and the company. Ex. promotion, termination of the labour relations, disciplinary measures);
- Environmental issues;
- Fraud;
- Harassment;
- Information security;
- Safety issues;
- Theft;
- Other compliance related issues which are not covered by the above-listed types.

Reporting channels:
•    The direct superior
•    The next superior hierarchy level;
•    The Legal or Compliance department or other corporate function such as Human Resources, Environment or Health & Safety or 
•    The Compliance Hotline “Speak Up” via Internet/app on the following link: https://heidelbergmaterials.speakup.report/speakup or  QR-code   

Besides the above the concerns can be communicated through (i) hotline 800-2100645; or (ii) mail/courier at the following address Devnya 9160, Industrial Zone, Bulgaria or at the address Varna, 115, Osmi Primorski Polk Blvd., fl. 4, Bulgaria to attn. Dilyana Bedzheva, Compliance Manager 

It is advisable to leave contact details to get back to you, if necessary, and when reporting an Incident the following should be included:
- Who acted? - full names of suspects and potential witnesses
- What happened? - brief but precise overview
- When did it happen? 
- Where did it happen? - name and address of the site/plant where the incident occurred
- Why did it happen? - reasons/factors that led to the incident (background)
- What happened? - course of events

Although the personalized reporting is preferred for accelerating the facilitating and investigation process, full confidentiality is still warranted to reporting employees and anonymous reporting remains an option in case of sensitivity. 

Raising untrue allegations in a bad faith is a misuse of the compliance incident reporting system and may itself be regarded as a compliance incident resulting in sanction for the reporting party. 

All submitted incident reports, irrespective of the reporting channel, are to be handled in a way which avoids any retaliation towards the reporting employee.

Confidentiality: All persons to whom incidents are reported are obliged to handle the cases confidentially.