Our framework for reporting potential irregularities in confidence, ensuring transparent investigations and full protection under the Protected Disclosures Act 2014.
1. Objective, purpose & scope of application
1.1 Objective
Confluence Talent (hereinafter also referred to as “we” or “us”) pursues the goal of preventing unlawful behaviour in our area of responsibility at best, but in any case to comprehensively clarify and remedy it. In doing so, we rely on the trusting assistance of whistleblowers, whose protection we want to ensure against this background.
1.2 Purpose
This policy sets out the framework conditions for reporting information on possible legal violations in our organisation. The policy is intended to ensure that reports of violations can be processed, stored, forwarded and archived in accordance with the legal requirements of the Protected Disclosures Act 2014 and taking into account the necessary confidentiality.
At the same time, the Policy describes the safeguards that exist in the interests of bona fide whistleblowers and the consequences that can result from a deliberate false report.
2. Whistleblower entitlement
Natural persons who obtain information about violations under our responsibility in connection with their professional activities or in the run-up to such activities are entitled and encouraged by us to report such information.
Scope of eligible persons
This applies in particular to our employees, job applicants, management personnel, contractors, and our business partners across European operations.
2.1 Reportable offences
Offences can be reported if they:
Are punishable by law,
Are subject to fines, e.g. violations of occupational health and safety regulations, health protection, or violations of the Minimum Wage Act,
Violate federal or state legislation or directly applicable legal acts of the European Union and within the meaning of Section 2 para. 1 no. 3 of the Whistleblower Protection Act, e.g. public procurement, environmental law, data protection,
Violate corporate guidelines or rules of conduct.
Exclusion notice
Please note that the whistleblower system is not intended for submitting general complaints, commercial enquiries, or warranty claims.
2.2 Reporting procedure
2.2.1 Internal or external message
Whistleblowers are free to report via the reporting channels specified and provided by us or to an external body, i.e. a competent authority.
External reporting channel
Information on external reporting procedures can be submitted via the designated reporting address:
When reporting electronically or in writing, please remember to include all information necessary for correct classification. It is particularly important to state that the report relates to processes in our organisation.
3. Confidentiality & safeguards
Guaranteed confidentiality
All reports are treated with strict confidentiality. Identity disclosures are strictly limited to authorized investigative personnel unless disclosure is mandatory by law.
The company guarantees protection from any form of retaliation, discrimination, disciplinary penalty, or contractual disadvantage for individuals who raise concerns in good faith.
Conversely, deliberately false or malicious allegations will not be afforded protection and may result in appropriate disciplinary action or legal proceedings.
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