Policies

Germany Whistleblowing Policy

Supplementary Policy to the Bloomberg Core Guide & Bloomberg Contingent  Worker Policy Guide regarding Whistleblowing in Germany

 

In light of the new Whistleblower Protection Act/Hinweisgeberschutzgesetz, the following supplementary policy to the Bloomberg Global Resource and Information Core Guide & Bloomberg Contingent Worker Policy Guide (‘Guides’) applies in Germany as of 17 December 2023. This policy applies to Bloomberg employees (hereinafter referred to as “Employees”) as well as to our contingent workers (including agency workers and freelancers) (hereinafter referred to as “Contingent Workers”).

Which information can be reported?

Employees and Contingent Workers are able to report information about (potential) violations of applicable law related to their professional activities at Bloomberg.

Where can Employees and Contingent Workers report to?

  1. Employees and Contingent Workers shall primarily report to the Bloomberg Ethics Hotline (being the required internal reporting body).
  2. If they wish, Employees and Contingent Workers can alternatively raise any concerns with the Human Resources team directly by contacting the Global Head of Employee Relations.
  3. Alternatively, if they choose to do so, Employees and Contingent Workers can also directly contact external reporting bodies. Such bodies have been set up at the Federal Office of Justice (Bundesjustizministerium), the Federal Cartel Office (Bundeskartellamt) and other authorities.

How can Employees and Contingent Workers report violations to the internal reporting body?

  1. To report a breach, Employees and Contingent Workers should visit the Bloomberg Ethics Hotline at the following link: https://bloomberg.com/hotline.
  2. Using this link, Employees and Contingent Workers are presented with two options to report violations. They can either report the violation orally by using the telephone number available in the above link or they can use the electronic form provided via the above link to report a violation in text form.

What happens after a report to the internal reporting body has been made?

  1. Bloomberg L.P. will acknowledge receipt of the report.
  2. Bloomberg L.P. will investigate the reported violation and initiate appropriate follow-up measures, such as internal investigations or referral to the public prosecutor’s office. In doing so, Bloomberg L.P. will keep in contact with the reporting Employee or Contingent worker.
  3. Reprisals against the reporting Employee and Contingent Worker, such as dismissal, are prohibited by law and are not to be feared.

Applicability of the Whistleblower Protection Act

The provisions of the Whistleblower Protection Act/Hinweisgeberschutzgesetz apply in the handling of any reports under this Act.