Whistleblower Protection

What can be reported

Reports of legal violations related to our business activities are reportable – such as violations of data protection, sanctions or competition law, corruption, or significant violations of this Code of Conduct. Uncertainties ('is this okay?') may also be raised; better one question too many.

Reporting Channels

Please send reports to [email protected] with the subject line 'Confidential Notice' or by mail to the management, Baduno GmbH, Mainzer Landstraße 166, 60327 Frankfurt am Main, with the reference 'Personal/Confidential'. We will treat your identity confidentially upon request; we also process anonymous reports, provided they are verifiable.

How We Process Reports

We confirm receipt within seven days. The review is carried out by management, involving external advisors where necessary; we inform you of the outcome or status within three months. Documentation and storage are handled confidentially and separately from other correspondence.

Protection of Reporting Persons

Retaliation against persons who report in good faith is prohibited – under labor law, contractually, and de facto. This applies to employees as well as freelancers in our network and employees of business partners. Abusive, knowingly false reports do not enjoy this protection.

Step-by-Step Practical Example

Suppose a freelance translator from our network discovers during a project that personal data of clients is being stored in an unsecured cloud, contrary to internal policies. They wish to report this but are unsure of the exact procedure.

Step 1: The translator sends an email to [email protected] with the subject line "Confidential Report" and briefly describes the incident, without providing a legal assessment. They can indicate whether they want to be named or remain anonymous.

Step 2: Management confirms receipt of the report within seven days. The confirmation states that the review has been initiated.

Step 3: The review is conducted by management, involving external consultants if necessary. The secure cloud configuration is examined and corrected if needed.

Step 4: Within three months, the translator receives feedback on the outcome or current status. In this case, they are informed that data security has been restored.

Throughout the process, their identity is treated confidentially if they so wish. The report is documented and stored separately from other correspondence.

Common Misunderstandings

In connection with whistleblower protection, we frequently encounter questions based on uncertainties. A common misunderstanding is that a report is only permissible if the whistleblower can already prove the violation beyond doubt. In fact, a concrete suspicion or a request for clarification ("is this okay?") is sufficient; the review is carried out by management.

Another misunderstanding concerns anonymity: those who do not provide their name can still submit a report. However, investigating anonymous reports is sometimes more difficult because follow-up questions are not possible. We strive to review anonymous reports as far as they are verifiable.

Some fear that a report automatically triggers labor or contractual proceedings against the accused person. This is not the case. The initial goal is to clarify the facts and, if necessary, remedy the situation. Further steps may follow only in the case of confirmed, serious violations.

Finally, it is occasionally assumed that protection against reprisals also applies to deliberately false accusations. That is not correct: anyone who knowingly submits a false report is not protected and must expect consequences.

What This Specifically Means for Customers

Our B2B clients – for example, companies that have us localize their websites – are indirectly affected by our whistleblower protection system. For instance: a quality manager at a client company observes during a joint project review that Baduno is internally violating license terms (e.g., using unlicensed software). She wants to report this without straining the business relationship. In such cases, she too has access to the reporting channel: she can send an email to [email protected] with the subject line “Confidential Report.” The management treats the report confidentially and reviews it independently of day-to-day operations. The report is only shared with the client contact with the reporting person’s consent, to avoid any disadvantages. Clients can rely on us taking reports seriously and closing compliance gaps. This strengthens the partnership and avoids risks for both sides. The reporting person (even if not employed by Baduno) is protected against retaliation, provided they act in good faith. We recommend that our clients inform their employees about this option – for example, by mentioning it in the collaboration policy. A functioning whistleblower system benefits everyone involved.

Interplay with Our Other Policies

The whistleblower system is not an isolated measure but part of our comprehensive compliance framework. It complements existing policies such as our Code of Conduct, Data Protection Policy, and specific rules on corruption or competition law. Reports submitted via the whistleblower system may relate to violations of any of these regulations. We review each report in the context of the relevant policy and involve the respective policy owner if necessary. For example, a report about a data protection breach is handled using the same methodology as a report about a violation of our Code of Conduct. The reporting channels are centrally bundled, so you do not have to decide which policy applies. Our internal team ensures correct categorization. At the same time, specific reporting channels exist alongside the whistleblower system – for instance, for data protection matters directly to our Data Protection Officer. The whistleblower system is designed as an additional, confidential channel that can be used even if you are unsure whether a report belongs under a special procedure. We coordinate the handling internally to avoid duplication and ensure a consistent assessment.

Internal Process at Baduno

Upon receipt of a report, it is immediately recorded in a protected system separate from other correspondence. Management or an appointed person – in case of conflict of interest, an external ombudsperson – carries out an initial assessment. This assessment examines whether the report is plausible and falls within the scope of the whistleblower system.

Subsequently, the facts are investigated. This includes reviewing documents, interviewing persons providing information, and, if necessary, involving external advisors. The results are documented in a confidential report. We inform the reporting person about the progress or outcome within three months – provided we can reach them.

All documentation is retained for the legally required period after the conclusion of the procedure and secured against unauthorized access. Responsibilities are distributed to avoid conflicts of interest. For example, reports against members of management are automatically forwarded to an external body. This internal procedure ensures that every report is taken seriously and examined without bias.

Our Internal Procedure

After receipt of a report, it goes through a defined internal process. First, the report is recorded by management and an acknowledgment of receipt is sent to the whistleblower if contact details are available. The report is stored in a separate, confidential folder that is distinct from other correspondence. The review is conducted by management; external advice is sought if necessary, for example in complex legal matters or to ensure the independence of the internal review. The review includes gathering facts, interviewing affected persons, and evaluating documents. The documentation is continuously updated and retained for the legally required period after the case is closed. We inform the whistleblower about the progress within three months. Throughout the procedure, the whistleblower's identity is kept confidential unless they consent to disclosure. Abusive reports are not pursued after identification, and the protection for the reporting person lapses in such cases. The internal process is designed to ensure a fair and thorough review.

Interaction with Our Other Policies

The whistleblower protection page is not to be considered in isolation, but supplements our existing internal policies. For example, our Code of Conduct sets out general principles of integrity and compliance, while the whistleblower protection page describes the specific reporting process. The Data Protection Policy governs how we process personal data – including in the context of a report. When you submit a report, we ensure that your identity is treated confidentially to the extent you wish, and that the data is used only for the purpose of the investigation. The Anti-Corruption Policy, in turn, defines specific prohibitions, violations of which may also be subject to reporting. In the event of a report, these policies interact: Management reviews the matter in accordance with all relevant requirements. For example, a report of a data protection breach may activate both the whistleblower protection rules and the Data Protection Policy. We document the matter separately from other correspondence to ensure confidentiality. If an internal investigation is required, it will be conducted in accordance with the standards of the respective policy. This ensures that reports are handled consistently and transparently.

What this means for customers in practice

As a customer or business partner of Baduno, you have the opportunity to report violations related to our business activities – for example, if you observe that a Baduno employee is violating applicable law or our Code of Conduct. You do not need to prove that an actual error has occurred; a concrete suspicion is sufficient. You can submit your report confidentially or anonymously. We will review your tip carefully and within the statutory deadlines. Should you fear that you may suffer disadvantages as a result of your report (such as termination of a contract), rest assured: We will not make any inquiries to your contractual partner that could identify you as the whistleblower. Retaliation against reporting persons is prohibited. This applies regardless of whether you are directly contractually bound to us or only collaborating with us on a project. In practice, this means: You can send us an email at any time with the subject line 'Confidential Report' and describe the matter. We will confirm receipt within seven days and inform you of the outcome or status of the review within three months – without disclosing your identity, if you so wish.

Terms explained in plain language

To avoid misunderstandings, we explain here some key terms from the area of whistleblower protection: A whistleblower is any person who reports a legal violation in a professional context – be it an employee, a freelance translator from our network, a customer, or any other business partner. A report is the communication of such a tip via one of the named reporting channels. A good-faith report means that the whistleblower, when making the report, assumes that the information corresponds to the truth. Only such reports enjoy protection against reprisals. Reprisals are disadvantages inflicted on someone because of a report, such as warnings, termination, or contractual penalties. They are prohibited. A verifiable tip is a report that is so specific that management can investigate the matter – for example, with details of time, location, and parties involved. Anonymous tips can be verifiable if they contain sufficient details. Confidentiality means that your identity is disclosed only to those persons involved in the investigation and is not passed on to third parties. These terms help to better understand the process and resolve uncertainties.