Whistleblowing Hotline / Reporting Offices

Our promise to act professionally and in accordance with applicable laws and ethical values towards each other, our clients and the capital markets requires integrity in our words and actions. We are clearly committed to the values set by KPMG in the form of a Code of Conduct. Questioning applicable laws or our values is unacceptable. To maintain our culture of integrity, KPMG has long maintained a whistleblowing hotline in Germany.

What reporting offices does KPMG maintain?

In compliance with the legal requirements from the

• Act for Better Protection of Whistleblowers (Whistleblower Protection Act, "Hinweisgeberschutzgesetz", or “HinSchG”),
• Act on the Detection of Proceeds from Serious Crimes (Money Laundering Act, GwG)

and the

• Act on corporate due diligence obligations to prevent human rights violations in supply chains (Supply Chain Due Diligence Act, "Lieferkettensorgfaltspflichtengesetz", or “LKSG”).

KPMG maintains the whistleblower reporting channels described in more detail below. The so-called "Whistleblowing Hotline" is designed as an internal reporting office in the sense of Section 14 HinSchG and at the same time fulfils the function of a complaints office in the sense of Section 8 LKSG and as a whistleblower system within the meaning of Section 6 (5) GwG.

Moreover, external reporting offices are also offered at European level, for example by the European Commission, the European Anti-Fraud Office (OLAF) or the European Securities and Markets Authority (ESMA).

Who can use the Whistleblowing Hotline?

The Whistleblowing Hotline can be used by all employees within the meaning of Section 3 (8) HinSchG, but also by clients, subcontractors, suppliers and other third parties, including as a complaints office as defined by Section 8 LKSG.

Furthermore, the Whistleblowing Hotline is available to employees and persons in comparable positions as a whistleblowing system within the meaning of Section 6 (5) GwG.

What kind of information can be reported to the Whistleblowing Hotline?

The Whistleblowing Hotline allows the reporting of illegal or unethical behaviour when other channels of communication have proven to be less effective or inappropriate.

What is more, it can be used particularly for reporting and disclosing information on violations within the meaning of Section 2 HinSchG. This includes violations that are punishable by law or – insofar as the violated regulation serves the protection of life, limb or health, or the rights of employees or their representative bodies – are subject to a fine, or other violations of legal provisions, e. g. for the protection of personal data, the auditing of financial statements of public interest entities or the accounting of companies that are capital market-oriented.

Aside from that, it is also possible to report human rights or environment-related risks as well as violations of human rights or environment-related obligations within the meaning of Sections 8 and 9 LKSG as well as violations of the provisions on combating money laundering and terrorist financing as defined by Section 6 (5) GwG and any anomalies in this context.

The Whistleblowing Hotline can also be used to report misconduct by KPMG employees with regard to professional standards or against self-imposed values such as KPMG Germany's Code of Conduct.

We encourage everyone to voice their concerns if they affect KPMG in Germany or its employees or management. If your concern relates to a KPMG firm that is not a group company of KPMG AG Wirtschaftsprüfungsgesellschaft, please contact that KPMG firm directly or use the KPMG International Hotline, which can be accessed via the details at the following link.

How can a report be submitted?

KPMG operates the Whistleblowing Hotline as an internal reporting office with the involvement of an external lawyer based in Berlin: Dr. Margarete Gräfin von Galen, attorney at law. The involvement of a person outside the organisation who is bound by professional secrecy ensures confidentiality for everyone who submit a report, anonymity for those who do not wish to disclose their name and impartiality as they are independent and not bound by instructions. The Whistleblowing Hotline offers the following options for submitting a report:

• By telephone using the following number:

+49 30 31 01 82 15

You can reach attorney Dr. Margarete Gräfin von Galen at this telephone number during regular office hours (9.00 a.m. to 6.00 p.m.). Outside these office hours an answering machine is available to take messages.

• By post or e-mail to the following contact details:

Rechtsanwältin Dr. Margarete Gräfin von Galen

Mommsenstr. 45

10629 Berlin

galen@galen.de

• By using the web-based online reporting system *

From here, the report will be made available to attorney Dr. Margarete Gräfin von Galen and – unless the reporting person excludes the corresponding notification – to a close circle of employees in Quality & Risk Management at KPMG.

What happens to the reported information?

Each notification is processed in accordance with the legal requirements (in particular Section 17 HinSchG and Sections 8 and 9 LKSG).

The internal reporting office receives each report, confirms receipt, evaluates it, discusses the facts with the whistleblower and decides on the next steps for the clarification and investigation of the information, depending on the violations and/or anomalies reported. This is done in consultation between attorney Dr. Margarete Gräfin von Galen and the responsible persons from the Quality and Risk Management department appointed in accordance with Section 15 HinSchG. The internal reporting office determines the follow-up measures in accordance with Section 18 HinSchG.

Attorney Dr. Margarete Gräfin von Galen maintains contact with the whistleblower and informs him/her about the conclusion of the investigation and its result.

The content of every report and every reporting person within the scope of the Whistleblower Protection Act are subject to the protection of this act. Reports are treated in strict confidence; the anonymity of a whistleblower will also be maintained by attorney Dr. Margarete Gräfin von Galen at the request of KPMG employees in the internal reporting office.

Reports that do not concern KPMG in Germany but, for example, another KPMG company that is a member of the global KPMG organisation of independent member firms, are forwarded to KPMG International. If a report is forwarded to another group company of KPMG AG Wirtschaftsprüfungsgesellschaft or to KPMG International, it is subject to the appropriate rules for the protection of confidentiality and against retaliation.

KPMG encourages reporting violations of laws and ethical principles. Whistleblowers and in particular employees need not fear any negative consequences (Section 36 HinSchG) for a report they submitted in good faith within the meaning of Sections 33 and 34 HinSchG or whose submission they have supported (Section 36 HinSchG). KPMG Germany's Code of Conduct prohibits sanctions against anyone who reports a possible violation in good faith or participates in an investigation, even if there is insufficient evidence to substantiate the concerns raised.

_{* KPMG in Germany cooperates with Clear View Strategic Partners** in Canada, an independent provider of web-based hotline services.  Please note the instructions in the reporting system, especially with regard to the options for preserving anonymity.}

_{** Clear View ConnectsTM is a registered trademark of ClearView Strategic Partners Inc.}