whistleblowing@thyssenkrupp Materials Hungary

At thyssenkrupp Materials Hungary Zrt. integrity, compliance with the law and internal regulations are of highest priority. To ensure that these values are upheld and potential risks arising from violations are avoided or minimized, it is crucial that misconduct is identified, clarified, and remedied at an early stage. To this end, tk encourages you to report suspected misconduct. Every indication of a potential misconduct are treated seriously and lead to an investigation following an objective and transparent process without any bias. thyssenkrupp Materials Hungary Zrt therefore makes available to whistleblowers in compliance and under protection of the Hungarian Whistleblowing Act, an internal information system that enables whistleblowers to submit reports.

Individuals who report misconduct to thyssenkrupp Materials Hungary Zrt are now additionally protected by the Act no. XXV of 2023 on Complaints and Reports of Public Interest and the Rules of the Handling of Reports of Abuse (“Whistleblowing Act”) transposed the Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019 on the protection of persons who report breaches of EU or Hungarian laws.

Since the 25th of September 2024 entities with more than 50 employees need to implement the according measures, especially the activation of a reporting channel and establishment of investigation procedures that guarantee, among others, the confidentiality of the report and the protection of the whistleblower against disclosing its identity and any retaliation resulting from the report.

A detailed description, the thyssenkrupp whistleblowing rules of procedure thyssenkrupp Materials Hungary Zrt can be found as attachment of this page.

1. Who can inform about a violation?

The whistleblower is any natural person who submits the report or makes a public disclosure of information on violations acquired in the context of his or her work. This includes but is not limited to:

· staff with an employment relationship

· self-employed workers

· freelancers and consultants, suppliers, customers

· volunteers and trainees

· shareholders or owners of company shares persons with administrative, management, supervisory or representative functions

· any person working for or under the supervision and direction of contractors, subcontractors and suppliers.

2. What can be reported?

Violations of internal regulations and/or applicable laws, including violations of the Hungarian Criminal Code and the internal Code of Ethics (e.g. corruption, embezzlement, misappropriation of funds, fraud), violations of human rights and environmental-related breaches of duty or risks as well as breaches of European law can be reported through a variety of reporting channels. Even indications or suspicions of violations can be reported and will be treated seriously. Therefore, in this document “violations” will refer to both actual and potential violations.

3. Who is responsible for dealing with reports?

The company has appointed it’s Compliance Manager of [company name] as the responsible for the internal whistleblowing system and procedure (“System Manager”). The System Manager safeguards that all requirements of the Whistleblowing Act regarding the operation of the reporting channel, the protection of the whistleblower and the conduction of the investigation are fulfilled. The System Manager entrusted with the management of the whistleblower system offers a guarantee of impartiality, is independent, is not bound by instructions and is sworn to secrecy. Incoming reports, that can also be submitted anonymously, are treated confidentially and whistleblowers are protected by all appropriate means against any disadvantages resulting from a report.

4. Whistleblowers may submit a report through various channels described below:How can I submit a report?

An open communication culture is an essential component of well-functioning compliance. Employees must be able to address potential violations openly, anonymously and, above all, at an early stage. To this end, we offer different channels which can be used to report any misconduct concerning issues listed in the Whistleblowing Act and any violations of the Hungarian Criminal Code.

For this purpose, thyssenkrupp Materials Hungary Zrt makes a number of internal whistleblowing channels available which are set out below:

4.1 thyssenkrupp Electronic Whistleblowing System (BKMS)

The Compliance Whistleblowing System of thyssenkrupp can directly be accessed https://www.bkms-system.net/tk-hu or by scanning the QR code below:

(The link or QR code will take you to the Compliance Whistleblowing System in Magyar. You can select another language on the landing page, e.g. English, to submit your report in the Compliance Whistleblowing System.)

In addition to the Compliance Whistleblowing System, violations regarding the International Framework Agreement (thyssenkrupp internal HR violations) can also be reported to representatives on the International Committee and the Labor Relations department at thyssenkrupp AG under https://www.bkms-system.net/frameworkagreement

4.2 Telephone Hotline

thyssenkrupp contact via the following telephone number selecting Polish language (automated telephone dialog):

Phone: +36 170 118 07

Access PIN: 4541

4.3 Contacts within thyssenkrupp Headquarters

thyssenkrupp Headquarters can be reached via the following contact details :

thyssenkrupp AG,

Compliance, Department Investigations

thyssenkrupp Allee 1,

45143 Essen, Germany

4.4 Contacts within thyssenkrupp Materials Hungary Zrt

The report can be submitted to the System Manager via email samu@nemeth.law, in person or by mail at/to the following address: 1158 Budapest, Fázis str. 6., Hungary

An external legal advisor has been contracted for the purposes of assisting the Company in connection with the assessment and handling and investigation of the report. The external legal advisor is engaged in line with Article 22 (4) of the Whistleblowing Act; i.e. the facts that there is no conflict of interest and that the law firm/lawyer is impartial are ensured.

If you work for thyssenkrupp, you can also contact your compliance manager responsible for your company directly. A detailed list of contacts is available on the intranet.

Please note: If a face-to-face meeting is requested, it will be organized within 7 days. If the report is submitted orally, with prior consent of the whistleblower, the report is documented in a secure, durable and accessible format, or by a transcript of the conversation. The whistleblower may be given the opportunity to verify, rectify and confirm the minutes of the meeting by signing them.

More information on the submission of reports to thyssenkrupp can be found here: Submitting a report (thyssenkrupp.com)

4.5 External Reporting Channels

We encourage whistleblowers to use our internal reporting channels. Whistleblowers also have the option to submit their report to an external reporting channel:

Depending on the subject matter of the report (the potential wrongdoing), the whistleblower may submit a report to any of the following external reporting channels, namely,

· a) the protected electronic system of reports of public interest, kept by the Commissioner of Basic Rights (this channel being the general external reporting channel) (https://www.ajbh.hu/en/kozerdeku-bejelentes-benyujtasa),

· b) the Directorate-General for Auditing European Aid (https://eutaf.hu/panaszbejelentes),

· c) the Office of Economic Competition

(https://www.gvh.hu/fogyasztoknak/hogyan_fordulhat_a_gvh_hoz/panasz_es_bejelentes/panaszurlap/panasz-urlap),

· d) the Integrity Authority (https://integritashatosag.hu/magunkrol/visszaeles-bejelentes/),

· e) the Public Procurement Authority (https://www.kozbeszerzes.hu/tevekenysegek/jogalkalmazok-tamogatasa/kozerdeku-bejelentesek/),

· f) the Hungarian Energy and Public Utilities Regulatory Office (https://makovg.hu/tavfutes/panaszkezeles/),

· g) the Hungarian National Bank (https://www.mnb.hu/felugyelet/bejelentesek),

· h) the National Authority for Data Protection and Freedom of Information (https://naih.hu/panasz-vagy-kozerdeku-bejelentes-a-panasztorveny-szerint),

· i) the National Media and Infocommunications Authority

(https://nmhh.hu/cikk/241937/Tajekoztato_elkulonitett_visszaelesbejelentesi_rendszer_mukodteteserol),

· j) the National Atomic Energy Authority

· (https://www.haea.gov.hu/web/v3/OAHportal.nsf/web?openagent&menu=09&submenu=9_0),

· k) the Authority for the Supervision of Regulated Activities (https://sztfh.hu/hatosag/panaszkezeles/),

l) any other body designated by the Government by way of a decree.

5. Data Protection

While carrying out internal investigations, it will be ensured that the applicable data protection laws are complied with. Detailed information on the subject can be found here: Data Protection Information