Whistleblower Channel

Whistleblower Reporting Channel — UPC-Marathon, a Division of Nitrex

In accordance with the EU Whistleblower Protection Directive (Directive (EU) 2019/1937) and the German Whistleblower Protection Act (Hinweisgeberschutzgesetz), UPC-Marathon has established a confidential reporting channel for the reporting of potential violations of law or ethical standards.

Purpose

This channel enables employees, business partners, and other stakeholders to report concerns about potential misconduct, including but not limited to:

  • Violations of applicable laws and regulations
  • Financial irregularities or fraud
  • Corruption or bribery
  • Violations of environmental protection regulations
  • Health and safety violations
  • Data protection and privacy violations
  • Discrimination and harassment
  • Other violations of our Code of Conduct

Reporting

Reports can be submitted through the following channels:

Email: [email protected] Mail: Compliance Office, UPC-Marathon GmbH, Wiesenstraße 51, 40549 Düsseldorf, Germany

Reports may be submitted anonymously. However, providing contact information helps us investigate the matter more thoroughly and provide feedback on the outcome.

Protection of Whistleblowers

UPC-Marathon is committed to protecting whistleblowers in accordance with applicable law. We guarantee:

  • Confidentiality of the reporter's identity
  • Protection against retaliation, discrimination, or disadvantage
  • Fair and impartial investigation of all reported concerns
  • Feedback on the status of the investigation within the legally prescribed timeframes

Investigation Process

All reports are reviewed by the designated compliance officer. Reports are acknowledged within seven (7) days of receipt. The compliance officer will investigate the matter and provide feedback to the reporter within three (3) months, subject to confidentiality constraints.

External Reporting

In addition to this internal channel, reports may also be made to the competent external reporting authority. In Germany, this is the Federal Office of Justice (Bundesamt für Justiz).

This reporting channel is operated in compliance with all applicable data protection regulations. Personal data collected in connection with reports is processed exclusively for the purpose of investigating the reported concerns.