Ethics & Compliance at TTI Europe
TTI is a company with values that have been deeply ingrained in the company since its foundation and are known by all employees (this term includes: management, employees, apprentices, and all workers with a quasi-employee relationship). Compliant behavior based on integrity has the highest priority at TTI. Our employees are obliged to comply with their legal obligations as well as with the ethical values outlined in the TTI Global Code of Conduct & Ethics.
Reports of compliance violations at TTI Europe
At TTI, we do not tolerate any compliance violations by our employees. To ensure that our high standards of ethics and compliance with laws are met, TTI investigates violations immediately. In order to minimize harm from damages to TTI, our employees, and other stakeholders, it is necessary for us to become aware of the following events at the earliest possible time:
- Crimes (including violations of anti-money laundering and counter-terrorist financing regulations)
- Regulatory offenses that are likely to cause harm to life, limb, or health
- Violations of
- Human rights
- Laws concerning the protection of employees
- Laws concerning product safety or conformity
- Consumer Protection laws
- Laws concerning the protection of privacy or personal data (in terms of the GDPA)
- Supply Chain Due Diligence Act
- Environmental laws
- The Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources
- Import or export regulations (e.g., sanctions or embargoes)
- Dangerous Goods legislation
- Labor laws
- Public Health regulations
- International Trade laws (e.g., accounting and financial reporting standards)
- The security of network and information systems
- The Trade Secrets Protection Act
- Non-disclosure agreements
- The TTI Global Code of Conduct & Ethics
TTI stakeholders and employees are encouraged to report potential violations. Every report is fully investigated and consistently followed up. Any and all information received will be treated confidentially. The principle of presumption of innocence governs all investigations. For this reason, confidentiality is assured to the person(s) making the report and to the person(s) that are the subject of the report. Their legitimate interests are taken into consideration.
TTI ensures to those who make a report in good faith that no measures under Employment law or other retaliations will be taken.
Please note that knowingly and willfully disseminating false information is a criminal offense in many countries. False suspicions and accusations against a person can have severe consequences for that person in their personal and professional life. Grossly negligent and intentional misreporting may cause liability of the reporting party for damages.
Please only use the whistleblower system responsibly.
The TTI Europe whistleblower system
You have several options to submit a report to TTI – even anonymously if you wish. If you leave contact details with the report, you will receive an acknowledgment of receipt from us within seven (7) business days for each type of report. At a minimum, feedback will be provided, after 3 months to include measures taken or planned to be taken.
At TTI, problems should be addressed openly. Therefore, maintaining an open-door policy is essential for us. Employees should first inform their supervisor confidentially about potential compliance violations unless the supervisor is connected to the incident.
With our external stakeholders, we value our relationships characterized by trustful and open communication. They are invited to approach our company through contacts known to them or that are publicly available.
In addition, it is possible to report a violation via the following channels. The internal channels are to be used preferentially, provided that TTI can take effective action against the reported infringement.
1. TTI Europe Inbox
TTI Europe offers the option of reporting to the email inbox whistleblowing@de.ttiinc.com. If it is not possible for you to report in English or German, you can submit your report in your native language. We will use an online translation tool to translate your message. Therefore, please use easy-to-understand language in your message.
If you wish to report anonymously to this Inbox, you can use an email address that does not reveal your personal information (especially your name). For this purpose, you can, for example, register an email address with a "fantasy name" (please do not use another person’s name) with a reputable email provider. Various providers are offering this service free of charge.
Your report should answer these five questions:
What happened? Who was/is involved? When did it happen (e.g., date, time, period, duration)? Where did it happen? What evidence exists for the violation (e.g., documents, witnesses)?
A clear description of the situation, which can answer these questions, will help the responsible party to process your report as efficiently as possible. Please note that people outside your expertise and people unfamiliar with the locations can understand the description.
We may contact you via email for further inquiries on the report or our feedback.
2. Berkshire Ethics Reporting
Another option for filing a report is using the Berkshire Hathaway Integrity Hotline, available 24 hours a day, seven days a week. Like the TTI Europe Inbox, it can be used for reports in any language. Reports can be made digitally or by phone. Please note that the website is available in English, German, Spanish, French, Arabic, Chinese, and Slovenian.
3. Personal report
Please contact the Vice President Human Resources Europe or the Compliance Manager for personal reporting. Please arrange an appointment via whistleblowing@de.ttiinc.com.
If you wish to report in Italy only and in Italian language – following the Legislative Decree No. 24/2023 -, you have the opportunity to do so here.
TTI employees are welcome to contact the Vice President Human Resources Europe or the Compliance Manager directly.
4. Report by mail
A report by mail can be sent to the following address:
TTI, Inc.
Whistleblowing
c/o Compliance Manager
Ganghoferstraße 34
82216 Maisach-Gernlinden
Please give a possibility to contact you that TTI may use for the feedback required by law.
5. External notification to the competent authority
Internal reporting channels of TTI should preferably be used to submit a report. Reports can also be submitted in German or English to the reporting office at the Federal Office of Justice.
The following link provides further information and the electronic reporting form: https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html.
Other federal reporting offices can be found at the Federal Financial Supervisory Authority and the Federal Cartel Office. These offices accept reports on violations of the Money Laundering Act resp. Anti-trust Law.
Retention period for personal data
If you disclose your identity, your personal data is stored for as long as a legitimate interest of the company exists or if it is required by law. After that, this data is deleted in accordance with legal requirements.