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Insider Trading
Purchasing or selling shares or other securities based on the knowledge of non-public, price-sensitive information that has been acquired through the relationship with the company, or disclosing such information for similar purposes to third parties.
Bribery, corruption, conflicts of interest
Offering, promising or giving bribes or kickbacks or other benefits in kind (gifts, credit, etc.) to customers, suppliers, competitors, auditors, public officials (civil servants, contract staff, etc.) or any other person with a view to unlawfully influencing business or regulatory decisions or political processes.
Anti-competitive conduct, market abuse
Agreements or other concerted practices between companies that have either the purpose or the effect of restricting or suppressing competition (e.g. price-fixing, quota-fixing, market allocation).
Export controls
Breaches of this international, legal instrument, which focuses on the exchange of goods and services across borders when relevant to security policies. Export control can apply legal restrictions on the foreign trade transactions of a country or economic region in order to safeguard the respective country's or economic region's essential security interests, for example, or in order to disrupt the peaceful coexistence of nations.
Personnel-related topics in breach of the law, particularly discrimination, harassment, bullying
Reporting of violations of existing laws, especially discrimination, harassment, or Mobbing (in this context, it is important to respect the ANDRITZ Code of Business Conduct and Ethics, for example, or the laws on equal treatment). As violations in this area should be reported primarily through the works council or HR departments the following special regulation applies: Anonymous reports will not be pursued by GCC; if a mailbox is provided for an anonymous report, a message is sent to the whistleblower requesting that anonymity be relinquished, otherwise the report cannot be pursued further. Alternatively the whistleblower has the option of submitting the report directly to the works council and/or competent HR department. If the report is not submitted anonymously or anonymity is relinquished, the report is pursued according to the process laid down in the company agreement. In each case, the employer's duty of care must be strictly observed regardless.
Breach of data protection regulations
Reporting of violations of national data protection laws.
Facts relevant to procurement
Reporting of violations of the supplier code of business conduct and ethics, especially breaches of organization requirements and management responsibility, human rights and fair working conditions, environmental responsibility and sustainability, integrity in business transactions, export control, intellectual property rights, trade secrets and data protection, and suppliers obligations (the ANDRITZ Supplier Code of Conduct, for example, must be observed in this Connection).
Fraud, accounting fraud, breach of trust, money laundering, misappropriation of business and trade secrets
Misrepresentation of facts or legal relationships in order to prompt companies or a third party to inflict damage upon itself (e.g. fraudulent use of funds, etc.). Misrepresentation of the assets, liabilities, financial position, and profit or loss of the reporting company for the purpose of fraudulently representing circumstances other than those actually prevailing (e.g. assets are assessed at too high a value or liabilities at too low a value or are not shown in the balance sheet at all). Abuse of representation powers by conducting (or failing to conduct) a legal transaction or other legal act (e.g. management using company funds for non-purpose businesses). Concealing or disguising the origin of illegal funds (e.g. from drug and arms trafficking, smuggling, etc.) in order to launder and transfer such funds legally to the financial and economic system. Illegal procurement of intellectual property or know-how from competing companies and disclosing of the company's own business and trade secrets to competing companies in order to gain a personal advantage or an advantage for a third party.
Other serious offenses
"Other serious offenses" are potentially criminal acts, potentially criminal acts under administrative law, and/or potential breaches of internal regulations that could cause palpable or sustained damage to ANDRITZ's financial situation. Thus, this only means actions relating to the company. Bear in mind also breaches of environmental, security, or tax regulations in this connection.
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