4. Implementation of the Code of Conduct
4.1 Compliance organization
Voith has established a Compliance Committee which is responsible for implementing and enforcing the Code of Conduct.
The Voith risk management system (Corporate Guideline 03/01) provides for CFOs to act as compliance officers at the divisional level. They serve as contacts and are responsible for implementing the Code of Conduct. Within the individual Voith companies this task is assumed by the CFO or a manager appointed by the CFO of the responsible Group division.
Voith will provide its employees with information to help them comply with the law and the Code of Conduct. In particular, this will include training sessions on specific topics and selected areas of risk. If employees nevertheless have questions, they can submit them to the CFO of the company or Group division, to the responsible legal or human resources department or to the members of the Compliance Committee. In addition, Voith will establish a help desk to answer questions. The relevant contact data will be made known through suitable channels, including publication on the Compliance Intranet page.
4.3 Complaints and reports of misconduct
Any employee can and has the right to report a violation or suspected violation of the Code of Conduct to Voith. At the employee’s discretion, the contact for this purpose can be the direct supervisor, the responsible human resources employee, the CFO of the company, the CFO of the Group division or any member of the Compliance Committee. The necessary contact data will be made available throughout the Group through suitable channels, including publication on the Compliance Intranet page.
An employee who on the basis of tangible evidence honestly believes that the Code of Conduct has been or might have been violated and who makes use of the right to report this to Voith will not suffer any kind of retaliation. In each such case, Voith will take the necessary steps to protect the employee against such retaliation. To the extent possible and legally permissible, Voith will maintain confidentiality about the identity of any employee who follows this procedure to report a violation or suspected violation of the Code of Conduct. The same applies to the identity of employees who cooperate in the investigation of such violations or suspected violation.
4.4 Implementing regulations
Voith will issue additional regulations concerning the implementation of selected items in this Code of Conduct. These regulations will also deal with questions about interpretation and approval procedures.