Informants Protection Act
Documentation, Guidelines and Procedures for Internal Reporting Offices Pursuant to the Informants Protection Act § 17 (1) KAGB
According to the German Informants Protection Act (HinSchG), capital management companies are obliged to set up internal reporting offices in accordance with Section 17 (1) of the German Investment Code (KAGB) in order to ensure the protection of reporting persons. Q21 Capital InvAG with TGV has therefore developed an online form for employees, customers and other external persons. With this form, reports can be submitted in writing, both anonymously and by name.
Each report is recorded and processed by a qualified and designated person. Only this person has knowledge of and access to the report. Within seven days of receipt of the report, the reporting person receives an acknowledgement of receipt, and within three months at the latest, feedback on the action taken.
The notification office complies with the requirements of the General Data Protection Regulation (GDPR) and is reviewed annually and updated if necessary.
The responsible person for this reporting office is Dr. Maximilian Bader, Member of the Management Board of Q21 Capital InvAG with TGV. The auxiliary responsible person is Pascal Tilgner, also member of the Executive Board of Q21 Capital InvAG with TGV, this task. The employer ensures that both persons have the necessary expertise.
The process begins with the submission of a tip via the online form. Upon receipt of the notice, the responsible person is notified of its receipt via email. The tip is then reviewed for potential conflicts of interest. If the review indicates that the tip directly involves the processor or affects the processor’s interests, the matter is forwarded to the person responsible for the tip.
The tip is thoroughly reviewed to confirm the factuality and validity of the information provided and that all relevant information is present. An acknowledgement of receipt will be sent within seven days. If necessary, additional information will be obtained.
Once all necessary information is received, the tip is treated as a case. The responsible person investigates the allegations made, the seriousness of the possible offense, and any reporting requirements to public authorities. She initiates necessary investigations and comprehensive inquiries and is responsible for their coordination and direction. Initiates necessary follow-up and files external reports as required.
Once the case is closed and appropriate measures have been taken, the responsible person informs the reporting person within three months about the progress and closure of the case and the measures taken.
Informants Protection Law Form
You can submit tips anonymously. Your tip will be treated confidentially. For spoken tips, please use the upload function at the end of the document for your audio file.