Rules of procedure for the processing of tips

1. Introduction:
As a market leader and international company, we at Fressnapf | Maxi Zoo are always aware of our responsibility for ethical and lawful behaviour and therefore act on the basis of strict values and principles. Our corporate mission statement is based - regardless of hierarchy and position - on responsible and reliable dealings with colleagues, business partners, customers and animals. We also expect this responsible and reliable approach from our business partners along the supply chain, which is why we also require them to adhere to high standards with regard to the treatment of people and animals. 

Our whistleblower system is designed to help report suspected or actual violations of laws, applicable laws and other internal and external regulations to the Fressnapf Group anonymously or confidentially. The whistleblower system is therefore part of the Fressnapf Group's compliance management system.

2. scope of application: 
These rules of procedure apply to the receipt and processing of information of all kinds relating to suspected or actual compliance violations in the German companies of the Fressnapf Group and the associated supply chains. The complaints procedure described here includes the complaints procedure in accordance with the Supply Chain Act (SCA) and the Whistleblower Protection Act (WPA). The processes described in this complaints procedure apply to all information received via the reporting channels mentioned in section 3.2.

3. submission of notices:
3.1 Authorised group of persons:
Any person, regardless of their relationship to Fressnapf | Maxi Zoo, is entitled to report suspected or actual compliance violations within the Fressnapf Group and the associated supply chains via one of the reporting channels listed in section 3.2.  

3.2 Reporting channels:
Information on suspected or actual compliance violations can be reported to Fressnapf Holding SE via the following channels:
Irrespective of the reporting channel chosen, reports can be made anonymously or confidentially, stating the name. It should be noted that anonymity can only be guaranteed via the electronic whistleblowing system. All reports, regardless of the reporting channel and the form of the report (anonymous or confidential), are processed with the utmost confidentiality and under the protection of personal data.

3.3 Reference objects: 
Can be reported:
  • Actual or suspected violations of laws, other directly applicable legal provisions and other binding internal and external regulations
  • human rights and environmental risks as well as violations of human rights or environmental obligations due to business activities in our own business area or those of a supplier in accordance with the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz)
In particular, however, information on actual or suspected violations in the following areas can be reported:
  • Money Laundering Act (GwG)
  • Data protection
  • Environmental protection
  • Conflicts of interest
  • Manipulation of business documents/balance sheets
  • Antitrust and competition law
  • Violations of principles of behaviour in the workplace and human rights
It should be noted that product and service-related customer concerns and complaints will not be processed. These should be addressed directly to Customer Service at Furthermore, no concerns relating to franchise partner stores will be processed. All concerns relating to the stores of a franchise partner must be addressed directly to the responsible franchise partner.

3.4 Contents of the notice:
In order to process a tip efficiently and quickly, it is helpful to provide as much detail as possible. The following key questions can help the person providing the information to formulate their report:
  • Description of the complete facts of the case in chronological order:
    • What happened?
    • When did the incident occur/is the incident still ongoing?
    • Where did the incident take place?
    • Who is/are the person(s)/group(s) of people affected?
    • What damage resulted from the incident?
    • Who could be responsible for the incident?
  • Which law, legal provision or regulation has been violated and how does the violation relate to the Fressnapf Group? 
  • What evidence is available (photos, videos, documents, witnesses, etc.)?
  • What expectations do you have of the Fressnapf Group and what is the specific aim of the complaint? 
  • Have other people already been informed about the grievance (both within and outside the Fressnapf Group)?
The key questions listed here are intended to support the person making the notification in formulating the notification and to ensure and speed up the proper processing of the notification. It is not necessary to provide information on the aspects listed in the key questions in order to process the report. In order to ensure that the report is processed successfully and to clarify any queries that may arise, it is recommended that a means of contacting the person submitting the report be set up. When submitting a report via the electronic whistleblowing system, this contact can also be made anonymously.

4. procedure for processing a notification:
4.1 Confirmation of receipt of the notification: 
The whistleblower will receive confirmation of receipt no later than seven days after submitting the report via the electronic whistleblowing system.
If the notification is submitted by e-mail, the person submitting the notification will also receive an acknowledgement of receipt within seven days at the latest. If the notification is submitted by post, a written confirmation of receipt will be sent by post within seven days of receipt of the notification, provided that a sender is known.

4.2 Processing of information:
Initial assessment: Upon receipt of a report, Corporate Compliance first carries out an initial assessment of the report to determine whether the facts described in the report justify a more in-depth review and processing. If Corporate Compliance requires further information in order to carry out the initial assessment, the reporting person will be asked to provide further information. If Corporate Compliance determines during the initial assessment that the facts/allegations described in the report are irrelevant or that there is insufficient information to conduct further investigations, the case will be closed.

Clarification of the facts: Various investigations are carried out as part of the clarification of the facts. The scope and nature of these investigations depends on various factors, including the nature of the allegations made, the parties allegedly involved, the maintenance of attorney-client privilege and data protection and the confidentiality of information. Corporate Compliance may hand over responsibility for processing individual reports to other specialist departments or ask them for support in processing them, while maintaining confidentiality. Furthermore, Corporate Compliance is authorised to request additional information from the whistleblower. Corporate Compliance also examines whether the Compliance Committee should be involved in the processing of the report as part of the clarification of the facts. The decision to involve the Compliance Committee is made by Corporate Compliance on the basis of statutory regulations and internally defined criteria. 
The duration of the clarification of the facts depends in particular on the complexity of the matter, the necessary investigative measures, the availability of information and the parties involved. Corporate Compliance endeavours to clarify the facts as efficiently and swiftly as possible. The whistleblower will receive final feedback on the reported matter no later than 90 days after receipt of the report.

Results of the fact-finding investigation: Depending on the results of the fact-finding investigation, the Fressnapf Group will take measures to appropriately address any violation/risk identified. These measures may include the separation of employees or the termination of a supplier relationship.

4.3 Communication with the whistleblower
The whistleblower is authorised to provide further information on the reported process at any time. For this purpose, the whistleblower can use all the reporting channels listed under point 3.2, but it must be assumed that Corporate Compliance can clearly assign the additional information to the report.
Corporate Compliance will contact the whistleblower in the following situations:
  • Within seven days of receipt of the notice of confirmation of receipt
  • Between the confirmation of receipt and the final feedback to request additional information if necessary
  • Within 90 days of receipt of the report to provide final feedback to the person making the report

5. principles on the procedure for processing notifications:
5.1 Confidentiality:
Incoming information is received by lawyers bound to professional secrecy and compliance managers with special confidentiality agreements. In the event that other specialist departments need to be involved in clarifying the facts, the employees entrusted with processing the information will treat the information obtained confidentially towards other persons.
The identity of whistleblowers will not be disclosed if they so wish and if this is legally possible. Any statutory disclosure and reporting obligations remain unaffected by this. 

5.2 Protection of whistleblowers:
The protection of whistleblowers has the highest priority. Whistleblowers who report suspected or actual violations of laws, applicable regulations and internal and external rules and who do so in good faith and to the best of their knowledge do not have to fear any unfavourable measures under the scope of these Rules of Procedure. In the event of recognisable misuse of the reporting procedure, i.e. the reporting of information that is obviously irrelevant and does not require further investigation, legal action may be taken against the person making the report.

5.3 Impartiality:
Impartiality is ensured by organisational decisions. In particular, the employees of the Legal & Compliance department of Fressnapf Holding SE act independently of instructions when reviewing the information. 

5.4 Fair procedure:
The applicable laws and company regulations, as amended from time to time, are complied with during the clarification of the facts and the investigation.

5.5 Presumption of innocence:
Investigations are conducted neutrally and objectively in accordance with the presumption of innocence.

6. data protection: 
The review of reports received (including the deletion and storage of data) is carried out on the basis of data protection regulations (GDPR, BDSG) and the relevant internal company regulations. For further information on data protection, please refer to our data protection notice in the electronic whistleblower system.