Whistleblower Protection Act
At MinebeaMitsumi, employees always have the opportunity to confidentially and securely express concerns and provide information about possible misconduct regarding compliance with the law and internal regulations and the MinebeaMitsumi code of conduct (the Code of Conduct).
The Code of Conduct summarizes all the rules of conduct that are essential to the Group and provides our employees with reliable guidance.
Based on European and national whistleblower regulations, special protection applies to whistleblowers. These regulations govern the protection of persons who have obtained information about violations in connection with their professional activities and report this information to the designated reporting offices. They will not suffer any disadvantages as a result of legitimately reporting violations.
Every report is thoroughly reviewed, suspected cases are investigated, and any violations are consistently pursued and sanctioned.
The following contact points are available to our employees:
In the immediate work environment
Employees can contact people in their immediate working environment to ask questions about the Code of Conduct or to report violations. These include managers, senior management, data protection officers or members of the human resources department.
Whistleblower system
With the “LegalTegrity” whistleblower portal, we offer all employees the opportunity to report violations of misconduct, legal provisions, and internal company regulations – even anonymously.
The information provided is subject to confidentiality in accordance with legal provisions. Personal data is processed in accordance with the provisions of the General Data Protection Regulation (GDPR) and related national legislation. In addition, we are obliged to protect the identity of the whistleblower and the persons affected by the report to the greatest extent possible. This means that personal data will only be disclosed to the responsible persons at the internal reporting office and may only be disclosed in exceptional cases specified by law.
The identity of persons who report false information through gross negligence or intent is not protected from disclosure.
The Whistleblower system shall not be used to express:
- Personal opinions, criticism or defamation of management or of the qualifications of Company and/or Group executives,
- Discontent or disagreements with staff,
- Criticism or defamation of the personal conduct of other employees.
This system is available in several languages and allows for confidential dialogue secured by special encryption. Whistleblowers can decide for themselves whether they want to give their name or remain anonymous.
All reports submitted via the LegalTrity portal of the participating MinebeaMitsumi locations are received by the EU HR office located at MTCE (Julia Preiss & Petra Storz) and receipt is confirmed.
For case processing, the central reporting office forwards the report to the responsible case handlers (the Case Managers), who then initiate all further measures and bring the case to a conclusion.
Reports are documented in accordance with legal requirements. The documentation is deleted three years after the conclusion of the proceedings. The documentation may be retained for longer in order to comply with legal requirements, as long as this is necessary and proportionate.