ul. Nałęczowska 16
20-701 Lublin
Poland, European Union
contact@finanteq.com
+48 81 536 9692
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Copyright © FINANTEQ SA 2025
Finanteq S.A.
ul. Nałęczowska 16
20-701 Lublin
KRS: 0000521114
Senacor Technologies AG
Düsseldorfer Straße 13
65760 Eschborn
To be able to create and maintain a pleasant (working) environment at Senacor where people communicate openly and treat each other with respect, all employees, former colleagues, customers, suppliers and other stakeholders are encouraged to report compliance violations.
The so-called Whistleblower Act ("HinSchG", "Hinweisgeberschutzgesetz") provides a safe framework for people who want to report compliance violations relating to the company. The objective of the law is in particular to protect the whistleblower's identity. Another objective is to give whistleblowers certainty that they will not suffer any drawbacks from giving a tip. Accordingly, whistleblowers are to be protected from repercussions such as discrimination, termination or other claims, so that they can express their concerns without fear. Senacor is committed to protecting whistleblowers.
This policy sets the framework for the reporting information regarding potentially illegal conduct to a defined group of persons. At the same time, the various justified interests of the whistleblower, the persons concerned, as well as the interests of Senacor and the public are considered. In addition, this policy also creates the conditions that allow tips to be received, stored, processed, forwarded, and archived in accordance with the requirements of data protection and data security, and in observation of the warranted confidentiality. It should be noted that the whistleblower system should specifically not be used to voice general complaints, but that it serves exclusively for receiving and processing reports about actual or supposed compliance violations.
The contents of this policy apply to Senacor Technologies AG and its subsidiaries (together with its subsidiaries "Senacor"). This applies insofar as no mandatory national legal regulations for employees in Austria, Poland, Switzerland and Slovakia conflict with the application of the guideline.
The following terms are used consistently within the directive:
The personal designations used in this document refer equally to female, male and diverse persons. Double references and gendered terms are avoided in favour of better readability.
Tips regarding actual or suspected compliance violations can be reported by email via the reporting channel (speakup@senacor.com) or orally by phone or other voice messaging systems provided by Senacor. The whistleblower can choose if he wants to contact this internal reporting office or an external reporting office (see Section 4). Anonymous reports are processed as far as possible.
To be able to operate an effective and functional whistleblower protection system, it is essential to protect all submitted reports and the information transmitted in this regard.
The Compliance Team processes all reports confidentially and in observation of the legal regulations, especially the regulations under whistleblower and data protection laws. A confidentiality agreement must be signed by each officer processing a report. Any reference to the identity of the persons concerned in a report - whether the whistleblower himself or other persons named in a report - is protected. This is to prevent false suspicions and defamations as well as the influencing of potential witnesses. To assure this, the group of persons, who have full knowledge of the identity of the persons involved should be kept as small as possible. The principle of confidentiality must be observed foremost by the persons involved in the process and regarding all information that becomes known at any step of the way.
The reporting offices are authorised to process personal data to the extent this is required to fulfil the tasks specified in this policy. In deviation from Article 9 (1) GDPR, the processing of special categories of personal data by a reporting office is permissible when this is required for the fulfilment of its tasks. In that case, the reporting office has to provide specific and appropriate measures to protect the interests of the person concerned.
Receipt of a compliance case does not automatically mean that there has actually been a legal violation. Senacor is obligated to review this and take appropriate measures if applicable. For this purpose, Senacor has established a whistleblower system, the so-called internal reporting office, which enables the reporting of information relating to legal violations. Senacor appoints the employees of the Compliance Team to maintain this whistleblower system. The reporting office is independent and impartial. It receives the reports, carries out the procedure initiated and takes any follow-up measures.
Receipt of the report is confirmed within seven (7) days. The internal reporting centre will provide feedback to the whistleblower within three (3) months after confirmation of receipt of the report. Based on the principle of confidentiality according to the respective whistleblower protection law (e.g. § 8 HinSchG or Art. 27 Ustawy o ochronie sygnalistów), the identities of the whistleblower and of the persons who are subjects of a report may be disclosed only to the competent persons in the internal reporting office.
Violations can be investigated, and measures can be taken initially at the internal level via the Senacor reporting channel. Reports can be submitted directly via email (speakup@senacor.com) or orally by phone or other voice messaging systems to the Compliance Team, which is responsible for the receipt and processing of reports.
Employees can also contact their leads or trusted representatives, and file reports through them with the internal reporting office. It is important to note that a reporting procedure is initiated only at the time when the tip is officially received by the internal reporting office. This ensures the appropriate protection of the whistleblower.
Follow-up measures include, in particular:
Alternatively, to the internal reporting office described above, whistleblowers may also directly contact the external reporting offices. In Germany, the external reporting office are, depending on the respective case, the German government at the Federal Office of Justice, the Federal Agency for Financial Market Supervision, and the Federal Cartel Office, and the external reporting offices of the states if these have corresponding jurisdiction. In Poland, the external reporting office are the Commissioner for Human Rights and competent public administration authorities.
It should be noted that in these cases, the investigation of the report and the implementation of requirements under the Whistleblower Act is exclusively the responsibility of the external reporting offices. Senacor does not accept any responsibility in this regard nor ensure protection measures.
All reports, including references to the whistleblower, will be processed confidentially and within the scope of the applicable laws.
Senacor prohibits any kind of repercussions for the reporting of a violation or for other cooperation in the investigation of a violation. It is pointed out that no such protection from repercussions will be granted in case of knowingly false reports.
In its investigations, Senacor aims to protect the justified interests of other persons who are affected by a disclosure. Senacor strictly adheres to the principle of the presumption of innocence and the "need to know" principle in its investigations.
The whistleblower system has the sole purpose of receiving and processing reports about actual or supposed violations of laws, policies or the Code of Conduct. Whistleblowers are only to submit reports which they believe in good faith to be true statements of the facts. If the whistleblower knows that a reported fact is untrue, he is not acting in good faith. If the whistleblower is not sure about the facts, this should be expressed as a suspicion, evaluation or statement of others.
If the whistleblower reports untrue facts about others against his better knowledge, it should be pointed out at this juncture that this constitutes a compliance violation which can entail consequences under criminal law. The identity of the whistleblower who reports false information will not be protected.
The effectiveness of the whistleblowing procedure is reviewed once annually and whenever there is a specific reason to do so. Senacor reserves the right to change this Whistleblower Policy at any time in due consideration of the employees' interests and to announce these changes.
If individual provisions of this policy should be or become fully or partly invalid, this shall not affect the validity of the remaining provisions. Instead of the invalid provision, such a provision shall apply that comes closest to the intended purpose of the invalid provision.
Compliance with this policy shall not release the employees from the duty to comply with statutory requirements.
ul. Nałęczowska 16
20-701 Lublin
Poland, European Union
contact@finanteq.com
+48 81 536 9692
Copyright © FINANTEQ SA 2025