WhistleBlowing Policy

1 Objective, purpose, scope of application

1.1 Objective

Confluence Talent (hereinafter also referred to as "we" or "us") pursues the goal of preventing unlawful behaviour in our area of responsibility at best, but in any case to comprehensively clarify and remedy it. In doing so, we rely on the trusting assistance of whistleblowers, whose protection we want to ensure against this background.

1.2 Purpose

This policy sets out the framework conditions for reporting information on possible legal violations in our organisation. The policy is intended to ensure that reports of violations can be processed, stored, forwarded and archived in accordance with the legal requirements of the protected disclosures act 2014 and taking into account the necessary confidentiality.

At the same time, the Policy describes the safeguards that exist in the interests of bona fide whistleblowers and the consequences that can result from a deliberate false report.

2. Whistleblower

Natural persons who obtain information about violations under our responsibility in connection with their professional activities or in the run-up to such activities are entitled and encouraged by us to report such information. This applies in particular to our employees, applicants, the management and our business partners.

2.1 Reportable offences

Offences can be reported if they

• are punishable by law,

• are subject to fines, e.g. violations of occupational health and safety regulations, health protection, violations of the Minimum Wage Act,

• violate federal or state legislation or directly applicable legal acts of the European Union and within the meaning of Section 2 para. 1 no. 3 of the Whistleblower Protection Act, e.g. public procurement, environmental law, data protection,

• violate guidelines or rules of conduct.

Please note that the whistleblower system is not intended for submitting general complaints, product enquiries or warranty claims.

2.2.1 Internal or external message

Whistleblowers are free to report via the reporting channels specified and provided by us or to an external body, i.e. a competent authority.

Information on the federal government's external reporting procedures can be found under the following link: pdcorrespondence@defence.ie

All reports are treated confidentially.

2.2.2 Type of message

When reporting electronically or in writing, please remember to include all information necessary for correct classification. It is particularly important to state that the report relates to processes in our organisation.