NODU GmbH Whistleblowing and Complaints System
NODU GmbH is committed to lawful, responsible and fair conduct. Employees, customers, suppliers, business partners and other people can use this system to report suspected violations, compliance concerns, human-rights or environmental risks and general complaints. Management operates the procedure voluntarily to identify, review and remedy concerns at an early stage.
I. What is the whistleblowing and complaints system?
The system enables employees, customers, suppliers, business partners and other people to report suspected legal or compliance violations, human-rights or environmental risks, and general complaints. It is operated voluntarily by NODU GmbH management to identify, investigate and remedy concerns at an early stage.
II. Who may submit a report or complaint?
Reports may be submitted by current and former employees, applicants, customers, suppliers, service providers, business partners and other people who become aware of relevant conduct connected with NODU.
III. What may be reported?
Reports may concern corruption, bribery, money laundering, fraud, theft, customs or sanctions, competition law, data protection, information security, product safety, occupational safety, discrimination, harassment, human rights, environmental risks, violations of NODU codes or other laws and rules.
General complaints about products, orders, invoices, deliveries, returns, customer service or business partners may also be submitted. Ordinary enquiries without a complaint or suspected violation should use NODU’s regular contact channels.
IV. How can a report or complaint be submitted?
Reports may be emailed to management@nodu-europe.com. Describe what happened, when and where, who was involved, whether it is ongoing, what evidence exists and whether it has already been reported. Only information necessary to review the matter should be provided.
Anonymous reports
Reports can be made through the anonymous reporting form without providing identity or contact details. Fully anonymous reports may prevent follow-up questions or individual status updates.
Other reporting channels
Reports may also be submitted by post to NODU GmbH, Olof-Palme-Str. 1, 51371 Leverkusen, by telephone on +49 151 64310985, or in a personal meeting arranged in advance. Reports may initially be submitted in German or English.
V. How are confidentiality and protection ensured?
Reports are treated confidentially and shared only with people needed to review them. A reporter’s identity is disclosed only where necessary and lawful, for example to investigators, authorities or courts or to pursue legal action. Where possible, the reporter is informed in advance. No identity is collected for anonymous reports unless identifying details are included by the reporter.
VI. Protection against retaliation
People who report in good faith must not be disadvantaged, intimidated, threatened or otherwise pressured, even if a suspicion is not confirmed. Retaliation can also be reported to management@nodu-europe.com.
VII. What happens after a report or complaint is received?
1. Acknowledgement
Where contact details are provided, NODU normally acknowledges receipt within seven days. An anonymous acknowledgement is possible only where the reporting channel supports protected communication.
2. Initial assessment
Management assesses whether the matter is understandable, sufficiently detailed, within NODU’s remit, urgent and whether more information is needed.
3. Follow-up questions
Where necessary and possible, the reporter may be asked for additional information or documents. Anonymous follow-up is possible only through a protected communication function.
4. Investigation
Plausible concerns are investigated carefully, impartially and confidentially. Measures may include reviewing documents and processes, interviewing people, contacting partners and involving external specialists. A case may be closed if it cannot be clarified or no misconduct, risk or justified complaint is found.
5. Preventive and remedial measures
Where a violation, risk or justified complaint is found, NODU considers proportionate measures such as process changes, training, technical improvements, product corrections, action involving employees or partners, ending a relationship, notifying authorities or taking legal action.
6. Feedback
Where contact details exist and feedback is lawful, the reporter normally receives an update no later than three months after acknowledgement. Feedback must not prejudice investigations, confidentiality, data protection, trade secrets or the rights of other people, and does not create a right to all findings or internal measures.
VIII. What happens to ordinary customer complaints?
Complaints about products, orders, deliveries, invoices, returns or services are forwarded internally. To assist handling, include the name or company, order or invoice number, product, description, purchase or delivery date, preferred contact method and relevant evidence. Anonymous complaints may prevent an individual remedy where the order cannot be identified.
IX. Deliberately false or abusive reports
Reports should be made in good faith. Proof is not required, but the reporter must reasonably believe the information to be true. Knowingly false, defamatory, misleading or abusive reports may result in employment, civil or criminal action. A report is not abusive merely because a suspicion is not confirmed.
X. What if the reporter was involved?
People who may have been involved can still report. Their involvement is considered appropriately but reporting does not automatically exempt them from legal or employment consequences.
XI. Are there any costs?
NODU does not charge for submitting or processing a report. Voluntary personal expenses such as independent legal advice are generally not reimbursed.
XII. Data protection notice
Personal data is processed only to receive, assess, document and handle the report, meet legal obligations and protect legitimate interests. This may include reporter and contact details, information about involved people, the facts reported, evidence, communications and necessary technical data.
Access is restricted to people needed for handling. Disclosure occurs only where required for investigation, legal claims, statutory duties or orders from authorities or courts. Data is retained only as long as necessary for handling, follow-up measures and legal retention duties, then deleted in accordance with law.
Anonymous reporting
No identity is required in the anonymous form. Reporters should also remove identifying information from descriptions, file names, images and documents. NODU seeks to avoid unnecessary identification data, although complete technical anonymity can be provided only within the limits of the systems used and applicable law.
XIII. Contact
Reports, compliance concerns and complaints: NODU GmbH, management@nodu-europe.com, Olof-Palme-Str. 1, 51371 Leverkusen, telephone +49 151 64310985. Personal meetings are available by prior appointment.