Dear colleagues, dear interested parties,

Below we inform you how the Whistleblower Protection Act is implemented at Antonov Logistics SALIS GmbH, Westringstraße 27, 04435 Schkeuditz, Germany and explain the system in 5 steps:

What is the Whistleblower Protection Act (HinSchG)?

The Whistleblower Protection Act (HinSchG) is the German implementation of the so-called EU Whistleblower Directive (Directive (EU) 2019/1937 of the European Parliament and of the Council of the European Union of October 23, 2019 on the protection of persons who report breaches of Union law).

What is the aim of the introduction?

The aim of the HinSchG is to protect persons who have obtained information about breaches in the course of their professional activities and report them. The HinSchG prohibits any reprisals against whistleblowers and obliges companies to set up secure channels for whistleblowing.

Which violations can be reported by whistleblowers?

Not every report of a breach of legal provisions is covered by the HinSchG. However, the scope of protection regulated under Section 2 HinSchG is very broad. Whistleblowers enjoy the protection of the HinSchG if they report violations of the following regulations:

• Violations of criminal provisions: This includes any criminal provision under German law.
• Violations that are punishable by a fine (i.e. administrative offenses) if the violated standard serves to protect life, limb or health or to protect the rights of employees or their representative bodies. This includes, for example, regulations in the areas of occupational health and safety, violations of the Minimum Wage Act or provisions on fines that sanction violations of the duty to provide information to works constitution bodies such as works councils.
• In addition, all violations of federal and state legislation that were adopted to implement certain European regulations are included, as well as violations of directly applicable EU legislation in a variety of different areas, such as: Regulations to combat money laundering and terrorist financing, regulations on product safety, regulations on traffic safety, regulations on the transportation of dangerous goods, regulations on environmental protection and radiation protection, food and animal feed safety, quality and safety standards for pharmaceuticals and medical products, regulations on consumer protection, regulations on data protection and information technology security, regulations on public procurement law, regulations on accounting for corporations, regulations in the area of competition law, etc.
• Most recently, the material scope of application was extended to include statements made by civil servants that constitute a breach of the duty of loyalty to the constitution.

Who receives and processes reports?

There is an internal reporting office and a HinSchG committee.

The QM department (Mr. Artem Kukoviakin), Development (Mr. Anatolii Moisiienko), Technical Director (Mr. Oleksiy Pervishko) and the Data Protection Officer (Mr. Jens Protze) are represented on the committee.

Where can tips be reported?

• By e-mail: message@antonov-logistics-salis.de
• By telephone: +49 34205 509541 (QM department)
• By post with the note Confidential to: QM department