The whistleblower system of the GWG Group

Responsible and lawful conduct is of the highest priority for the GWG Group. Only by adhering to our strict compliance principles and the applicable laws can the GWG Group, its bodies and employees be protected from legal consequences and possible damage to tenants, clients or business contacts be averted. It is therefore important for us to learn about possible misconduct at an early stage. This is the only way we can put a stop to it immediately. For us, all reports have the same relevance. Incoming reports and the identity of the whistleblower are treated with the utmost confidentiality.

Who can report violations?

Our employees, partner companies, customers, tenants and all other persons have the opportunity to report potential breaches of rules at any time and thus contribute to their detection.

What can be reported?

Confidential information about

- criminal offences committed by employees in the course of their work for the GWG Group (e.g. bribery or corruption, theft, fraud, embezzlement, disclosure of business secrets),

- other forms of improper business conduct,

- grievances that could endanger life or limb or cause damage to property

- possible violations by business partners of applicable law or the compliance principles for external business partners of the GWG Group.

must be reported.

What information should a report contain?

Reported circumstances can only be adequately investigated if sufficient information is available. Therefore, it is important for the processing of a report that it describes the underlying facts as concretely as possible. Whistleblowers should answer the following five questions: Who? What? When? How? Where?


What happens to tips received and how long does it take to process them?

The whistleblower will receive an acknowledgement of receipt of the report within seven days, unless the report was submitted anonymously. The whistleblower will be informed of any follow-up action planned or already taken, as well as the reasons for such action, within three months of confirmation of receipt of the report. In principle, reports are treated with high priority. Each report is first checked for plausibility. This may lead to queries by the Compliance Team or the GWG Group's lawyer of confidence. The duration of the processing depends on the scope and complexity of the reported facts.

What can be the result of a report?

If a violation of applicable law or internal regulations is confirmed, it will be remedied immediately. Necessary measures will be taken to prevent future violations of this kind (e.g. reviewing and improving processes or taking personnel measures).

What if reports turn out to be unfounded?

There is nothing wrong with submitting a tip-off because of a suspected violation of the law or rules. If a situation appears to be irregular and a tip-off is therefore made, this is courageous behaviour, even if a suspicion is not confirmed later.

This is to be distinguished from deliberately false information that unfairly incriminates other persons. Abuse is not tolerated.

Are whistleblowers protected?

Any form of discrimination against whistleblowers will not be tolerated. This includes, for example, intimidation of whistleblowers or negative consequences under labour law as a result of reporting. Discrimination against whistleblowers can also be reported as a violation through the channels mentioned above. 

How do we ensure confidentiality?

The offices responsible for processing the reports always treat the information provided confidentially. This applies in particular to personal data. During processing, the principle is observed that only the persons or offices necessary for processing are informed. Furthermore, the identity of the persons providing the information will not be disclosed, insofar as this is desired and legally possible. Legal or official notification obligations are excluded from this.

Can information also be submitted anonymously?

In principle, it is possible to submit information anonymously. However, clarification of the facts may require further inquiries. This should be considered if a whistleblower wishes to submit a completely anonymous report.