1. General

In accordance with Alu Menziken’s Code of Conduct, employees of Alu Menziken and its current and future subsidiaries (the “Alu Menziken Group”) as well as any persons working under the supervision and direction of contractors, subcontractors and suppliers of the Alu Menziken Group are encouraged and free to report, in accordance with this regulation, any concerns they may have regarding actual or suspected activities which may be illegal or in violation of Alu Menziken’s Policies, with respect to, without limitation, fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, and misuse of Alu Menziken’s assets, as well as any violations or suspected violations of Alu Menziken Code of Conduct (the “Allegations”).

The Alu Menziken’s Code of Conduct requires its employees and representatives to observe high standards of business and personal ethics in the performance of their duties and responsibilities on behalf of the Alu Menziken Group. The employees and representatives of the Alu Menziken Group are expected to practice honesty and integrity in fulfilling their responsibilities and are required to comply with all applicable laws, regulations and internal policies.

The objectives of this regulation (the “Whistleblower Regulation”) are:

  • to encourage and enable employees and representatives of the Alu Menziken Group as well as any persons working under the supervision and direction of contractors, subcontractors and suppliers of the Alu Menziken Group, without fear of retaliation, to raise concerns regarding suspected behavior so that the Alu Menziken Group can address and correct inappropriate conduct and actions;
  • to define the procedure for internal reporting of misconduct; and
  • to ensure the protection of individuals reporting Allegations from retaliatory actions.

2. Reporting Responsibility

It is the responsibility of all employees and representatives of the Alu Menziken Group as well as any persons working under the supervision and direction of contractors, subcontractors and suppliers of the Alu Menziken Group to report in good faith any Allegations in accordance with this Whistleblower Regulation.

3. Acting in Good Faith, No Retaliation

This Whistleblower Regulation is intended to encourage and enable the reporting of Allegations within the organization for investigation and appropriate action. With this goal in mind, no one who, in good faith, reports a misconduct shall be subject to retaliation or shall suffer intimidation, harassment, discrimination, termination, transfer, negative performance evaluations or the withdrawal of professional development opportunities or adverse employment consequences because of such report.

Moreover, an employee who retaliates against someone who has reported a concern in good faith is subject to disciplinary actions up to and including dismissal or termination of employment.

The act of making allegations that prove to be in bad faith and that prove to have been made maliciously, recklessly, or knowingly to be false, will be viewed as a serious disciplinary offense. It may also result in disciplinary actions, up to and including dismissal or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

4. Confidentiality

Any Allegations in accordance with this Whistleblower Regulation, and investigation pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation and be made accessible exclusively to those internal or external authorized entities. Disclosure of any information or identity details is strictly prohibited, exceptions exist only if a regulatory authority, court, or prosecuting agency deems such disclosure essential and proportionate within the context of an investigation. In such instances, the whistleblower shall, where feasible without compromising the proceedings, be promptly informed. Furthermore, any individuals implicated by the report (e.g., the accused) shall be accorded the same level of protection.

5. Procedure of a report in accordance with this Whistleblower Regulation

The employees and representatives of the Alu Menziken Group can report any potential misconduct, if preferred on a confidential and anonymous basis.
The internal reporting system is designed to be relatively simple and GDPR-compliant. Upon receipt of a written report, unless otherwise requested, an acknowledgment of receipt will be issued within a maximum of seven calendar days. Alternatively, reports may also be submitted verbally or in person, in which case the report will be documented

6. Investigations of reported misconducts

All Allegations will be promptly investigated; the scope of any such investigation being within the sole discretion of the designated person in charge of receiving, recording, reviewing, taking follow-up action and resolving reports, hereinafter referred to as the Designated Person and the board of directors of Alu Menziken Group and appropriate corrective action will be taken if warranted by the investigation. The designated person will notify the sender and acknowledge receipt of the Allegation within a maximum of seven calendar day.

The designated person shall be responsible for investigating and shall report to the Management of the affected location. In case the allegations concern the management of any group company the responsible shall also inform the Board of Management Alu Menziken Group.

Subsequently, it shall independently determine the extent and manner in which the investigation is conducted. The Designated Person shall be equipped with sufficient financial and human resources.

The Designated Person has the authority to retain outside legal counsel, accountants or any other resource deemed necessary to conduct a full and complete investigation of the Allegations.

Notwithstanding anything herein to the contrary, the scope, manner and parameters of any investigation of a reported misconduct shall be determined by Alu Menziken’s Designated Person in its sole discretion and in compliance with legal requirements. The Alu Menziken Group and its employees shall cooperate as necessary in any such investigation.

The designated person shall oversee the investigations and report to and make appropriate recommendations to the board of directors of Alu Menziken, with respect to all reported misconducts (the “Board of Directors”).

The designated person of the Alu Menziken is obliged to inform the reporting person of the outcome of the proceedings without undue delay after the conclusion of the investigations, or in case the investigations have not been completed yet about the status of the investigation, within 3 months of its receipt at the latest.

7. Data protection, documentation, recording and retention of reports

The processing of personal data obtained via the reporting procedure shall be strictly for the purpose of detecting, investigating, and preventing legal violations in the public interest.

In this regard:

  • Data Processing:
    Only data necessary for the investigation and resolution of the report shall be collected, processed, and stored. Data exceeding the investigative needs shall not be collected or shall be promptly deleted.
  • Confidentiality and Security:
    All personal data pertaining to the whistleblower, affected individuals, and any other persons referenced in reports shall be handled confidentially. Access to these data shall be restricted solely to authorized personnel. All modifications, inquiries, and data transmissions shall be comprehensively logged and securely maintained.
  • Acknowledgment and Documentation:
    Written reports will, be acknowledged within seven calendar days. For verbal reports, documentation shall be carried out through either an audio recording (subject to the explicit consent of the whistleblower) or a detailed transcript, which shall be presented to the whistleblower for review and confirmation.
  • Retention Period:
    Personal data collected and processed under this Regulation shall be deleted no later than five years after the last processing or transmission, unless a longer retention period is required by ongoing administrative, judicial, or investigative proceedings, in which case such storage shall be strictly limited to the duration necessary to achieve the intended purpose.

8. Information regarding the reporting procedure

To ensure transparency, the Alu Menziken Group is committed to providing clear and accessible information regarding its internal reporting procedure.

Specifically:

  • Information Provision:
    Detailed descriptions of the various reporting methods (written, telephonic, or in-person), including the option for anonymous and confidential submissions, shall be prominently displayed on the company website and through internal communication channels.
  • Procedural Steps:
    A comprehensive outline of the steps following the receipt of a report—from initial acknowledgment to investigation and feedback on corrective actions—shall be provided.
  • Protection Against Retaliation:
    It shall be explicitly stated that whistleblowers are protected against any retaliatory actions and that failure to adhere to these protections may result in legal and employment-related consequences.

9. Final provisions

This Whistleblower Regulation comes into force on 30-MAY-2025

Whistleblower system, Whistleblower Directive