Whistleblowing procedure

 

Procedure for complaints and notices

Responsible, ethical and lawful conduct is a top priority for O2 Telefónica in its own business activities and in its relationships with its business partners, customers and other stakeholders.
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O2 Telefónica has implemented a whistle-blower procedure which enables individuals, companies and other organisations such as non-governmental organisations to report human rights and environmental-related risks or violations as well as breaches of applicable law under § 2 of the German Whistleblower Protection Act (Hinweisgeberschutzgesetz / HinSchG) as well as other legislation, internal guidelines, internal guidelines, the Business Principles, the Declaration of Principles on Respecting Human Rights, the Supply Chain Sustainability Policy or concerns regarding a potential or actual infringement of these regulations. The purpose of the whistleblowing procedure is to ensure that all reports submitted are examined and processed transparently and fairly. To ensure that all persons affected by the actions of O2 Telefónica and its suppliers have effective access to this whistleblowing procedure, the website can be read aloud in German and English via the speaker icon in the path bar above. The Rules of Procedure are available in five languages.
Reporting Channels

Rules of Procedure

Complaints procedure / whistleblowing procedure
1. Foreword
2. Who can submit a report?
3. What topics does the whistleblower procedure cover?
4. To whom can I submit my report?
5. Can reports also be submitted anonymously?
6. What information should a report contain?
7. Who is responsible for processing the reports received?
8. How are reporting persons protected?
9. What happens after a report is submitted and how quickly are reports processed?
10. When will I receive information about the outcome of the procedure?
11. For how long will the information be retained?
12. Can a report also be submitted to external reporting offices?
13. Review of the effectiveness of the whistleblowing procedure according to §8 (5) LkSG
14. Accessibility of these Rules of Procedure according to § 8 (4) LkSG
15. Privacy information for whistleblowers

ANNEX I

Examples of the whistleblowing procedure
If you are unsure whether your report can be addressed via the channels, or what the correct reporting channel is, you can find examples here:
Example: Working conditions and occupational health and safety
TopicBackground informationRelevant reporting channels
Occupational health and safety incl. working timeOne-time or recurring disregard of applicable occupational health and safety regulations if this results in the risk of accidents at work and/or work-related health hazards (e.g. due to lack of safety standards, lack of protective measures; insufficient training and instruction). This also includes violations of the Working Hours Act, etc..Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Adequate wagesErrors in the remuneration process as well as withholding of appropriate wages (payment of salaries, overtime, bonus, etc.) not related to fraud. The appropriate wage is at least the minimum wage established under the applicable law.Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Child labourUnlawful employment of children under the age at which compulsory education ends according to the law of the place of employment, whereby the age of employment may not be less than 15 years, as well as unlawful disregard of the prohibition of the worst forms of child labour (e.g. slavery, prostitution, pornography, drug trafficking) for children under 18 years.Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Forced labour and slaveryThe use of labour akin to slave-like practices, such as slavery, human trafficking, debt bondage, servitude and sex work.Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Freedom of associationSituation in which employees are prohibited from joining a coalition and/or joining or forming a trade union, or are unjustly discriminated against on the basis of their membership of a coalition and/or trade union.Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Abuse of power by private and public security forcesHiring or using private or public security guards to protect the company's project if, due to a lack of instruction and/or control by the company, they do not respect the requirement of humane treatment and/or the freedom of association. Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Example: Protection of the environment and habitats
TopicBackground informationRelevant reporting channels
Environmental protection (to protect health and life)Causing harmful environmental changes such as soil pollution, water pollution, air pollution, noise emissions or excessive water consumption. Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Other environmental protection topics (to protect the environment and health)Use of mercury in products and production and treatment of mercury waste contrary to the provisions of the Minamata Convention. Use and production of persistent organic pollutants (POPs) and treatment of waste containing persistent organic pollutants contrary to the provisions of the POPs Convention. Import and export of hazardous waste contrary to the provisions of the Basel Convention.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Habitat protectionSituation of unlawful eviction and unlawful deprivation of land, forests and waters in the acquisition, construction or other use of land, forests and waters, the use of which secures the livelihood of a person.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Example: Information security / Data protection
TopicBackground informationRelevant reporting channels
Information security/ Data protectionUse of information of the company, customers, employees, shareholders or external partners for their own benefit or for the benefit of third parties. Violation of processes that guarantee the confidentiality, integrity and availability of sensitive company information.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Example: Actions that damage integrity or that are economically criminal
TopicBackground informationRelevant reporting channels
Conflicts of interestA conflict of interest exists in situations where a personal or private advantage or interest influences professional decisions of an employee and this personal advantage or interest conflicts with the interests of the Telefónica Deutschland Group.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Bribery of public officialsPromising, offering, paying, giving or authorising gifts, hospitality or any other type of inducement to a public official for the purpose of improperly influencing or obtaining an unlawful advantage.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Bribery in commercial transactionsPromising, offering, paying, giving or authorising gifts, invitations or other types of inducements to a business partner for the purpose of improperly influencing or obtaining an unlawful advantage. The same applies to the acceptance of benefits by employees who perform an act in breach of their duties in return.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Theft / embezzlement Fraud / InfidelityUnlawful appropriation of property belonging to third parties (e.g. the company, other employees, business partners). Procuring an unlawful pecuniary advantage by deceiving a third party or damaging the company's assets by breaching a fiduciary duty and causing financial damage.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Internal control system for financial reportingAccounting irregularities (accounting fraud) related to internal control over financial information.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Non-compliance with contractual obligations towards customersNon-compliance with obligations entered into with clients with regard to contractually agreed services, billing, quality of products and services, etc., as well as suspicion of theft of client data and/or company-sensitive information.Ombudsperson: www.telefonica.de/ombudsperson-en Whistleblower-inbox:
Example: Customer complaints
TopicBackground informationRelevant reporting channels
DiscriminationDiscrimination against persons outside of the employment relationship, especially against customers, residents of stores, etc.. Unequal treatment or arbitrary differentiation, e.g. on the basis of gender, religion, nationality, ethnic origin, sexual orientation, political opinion, disability, age, language, social origin. Discrimination can also be an isolated event that affects one person or a group of people in a similar situation.Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
OtherAny other indication by customers that cannot be attributed to any of the aforementioned characteristics and disregards the legal position of another person that is to be protected under applicable law.Ombudsperson: www.telefonica.de/ombudsperson-en Human Rights PO Box:
Example: Other
TopicBackground informationRelevant reporting channels
OtherAny other indication that cannot be attributed to any of the aforementioned characteristics insofar as concerns of the Whistleblower Protection Act are affected. The specified channels are not responsible for general customer complaints.Whistleblower-inbox:
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