Whistle Blower Policy | Steinway Gallery Singapore
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Questions & Answers about the Ombuds Office at MELCHERS  Group (“MELCHERS”)

What is an Ombuds Office?
The MELCHERS Group in Singapore (Steinway Gallery operated and owned by C. Melchers GmbH & Co., Singapore Branch) has appointed an external lawyer as ombudsperson in the course of fighting violations of legal regulations and/or internal company compliance rules. The ombudsperson is available as a contact person to all whistleblowers who wish to provide confidential information about serious irregularities committed by the Management, corporate bodies such as Boards or members of the Compliance department at the MELCHERS GROUP.

Who can contact the Ombudsperson?
The Ombuds Office is available as a contact person in principle to anyone who can provide information about unlawful conduct. This may be employees, customers or other third parties. The Ombuds Office accepts all reports about suspected violations that fall within the specified topic area.

What topics can I report?
The topics which can be reported include the following – in particular:

• Corruption, money laundering, bribery, financing of terrorism
• Anti-competitive behavior
• Violations of the Code of Conduct and other internal guidelines (e.g. purchasing guidelines)
• Product safety
• Discrimination, mobbing, fundamental rights
• Health, operational safety, occupational health and safety
• Human resources issues, including disregard of work instructions
• Data protection violations
• Antitrust violations
• Violations of EU-Laws

The Ombuds Office is not intended for complaints relating to operational day-to-day business. Information reported via the Ombuds Office that concerns matters outside the defined subject area will be forwarded to the appropriate contact persons subject to the whistleblower’s consent, or the appropriate contact persons will be named.

How can reports be submitted?
Information should be given as a matter of preference to the designated ombudsman’s office:

Ombuds Office / Ombudsperson:
Attorney-at-law Dr. Kathrin J. Niewiarra
Sybelstr. 7
D-10629 Berlin
Phone: +49 (0) 30 / 4036750-14
melchers-music.sg@compliance-aid.com

The complaints can be submitted in German and English.

How is my anonymity ensured?
As a lawyer, the ombudsperson is subject to the lawyer’s duty of confidentiality. The contact as well as all information and reports are treated absolutely confidentially. This is secured by a separate data protection agreement with MELCHERS as the client of the ombudsperson. Your identity will only be disclosed to MELCHERS with the express consent of the whistleblower. Should your information lead to investigations by law enforcement agencies, your anonymity is also guaranteed vis-à-vis these institutions by the lawyer’s duty of confidentiality.

What happens to my information?
The ombudsperson examines the incoming reports and undertakes an initial legal assessment. This is forwarded to Matthias Schubert or Angelina Rudolf at MELCHERS for further examination of the facts, provided that the whistleblower has consented to the forwarding. An absolute confidential treatment of the information is guaranteed. As far as the information can be substantiated, further measures will be initiated. If the information proves to be unfounded, the investigation will be terminated. In addition, all personal data will be deleted in accordance with data protection regulations.

Do I have to fear negative consequences if I make a report?
If you make a report to the best of your knowledge and belief, you will not suffer any disadvantages within the company. However, if you deliberately make a false report or report in bad faith, or if you yourself have violated applicable rules of conduct, MELCHERS reserves the right to take legal action.

What if the content of the report subsequently turns out to be false?
It is important that you believed or assumed that the content was true at the time of the report and that you did not make the report with abusive intent. If, after clarification of the facts, it turns out that the report was unfounded, you will not have to fear any negative consequences.

What happens if I am involved in the violation myself?
Even then, you are encouraged to report the facts in question. This will be taken into account appropriately, as far as legally possible, when investigating the facts and imposing any sanctions.

Do I, as the whistleblower, incur any costs by using the Ombuds Office?
There are no costs for the whistleblower.

Does my whistleblowing result in a client relationship with the Ombudsperson?
No, there is no client-attorney relationship. The ombudsperson is and remains the representative of MELCHERS. However, the legal relationship between the ombudsperson and MELCHERS as the client has a “protective effect” in favor of the whistleblower. As a result, the ombudsperson can informally advise the whistleblower on the practical issues of the individual case, but it is not possible for her to represent your legal interests as “your” lawyer.