Skip to main content

Whistleblowing Policy – SnowWorld Bispingen

Bispingen, October 2025

Table of Contents

  • What is a Whistleblower?
  • What Can Whistleblowers Report at SnowWorld Bispingen?
  • Who Can Be a Whistleblower at SnowWorld Bispingen?
  • When Are Whistleblowers Protected?
  • Through Which Channels Can Violations Be Reported?
  • External Reporting Channels
  • Public Disclosure of Information
  • What Happens After a Report Is Submitted to the Internal Reporting Office of SnowWorld Bispingen?
  • Prohibition of Disadvantages or Retaliation

We believe that whistleblowers make an important contribution to democracy and the rule of law by reporting legal violations and serious misconduct. We are convinced that individuals who report such violations should not be punished or suffer any other disadvantages as a result of doing so. We therefore support stronger legal protection for whistleblowers and are committed to applying this principle within our own organization. This policy explains how whistleblowing is facilitated at SnowWorld Bispingen.

1. What is a Whistleblower?

A whistleblower is not a traitor. Rather, the term refers to a person who discloses information of public importance from a confidential or protected context, for example in cases involving serious misconduct, fraud, health and safety risks, or other legal violations.

2. What Can Whistleblowers Report at SnowWorld Bispingen?

Whistleblowers may report violations covered by Section 2 of the German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG). These include, among other things, criminal offences and administrative offences punishable by fines where the violated provision serves to protect life, health, employees, or their representative bodies.

Reports may also concern violations of specific federal or state legislation, as well as directly applicable legal acts of the European Union or the European Atomic Energy Community relating to matters such as environmental protection, the protection of personal data, privacy in electronic communications, or information security.

3. Who Can Be a Whistleblower at SnowWorld Bispingen?

The following persons may act as whistleblowers:

  • Employees
  • Apprentices
  • Interns
  • External service providers

In addition, individuals whose employment has not yet commenced may report violations identified during the recruitment process or other pre-contractual negotiations. Former employees may also submit reports.

4. When Are Whistleblowers Protected?

Whistleblowers are protected against retaliation only if they had reasonable grounds to believe that the reported information was true and that the reported violation fell within the scope of the German Whistleblower Protection Act.

Protection does not apply where:

  • the report is knowingly or grossly negligently false;
  • the information was already fully public knowledge;
  • only speculation or rumours are reported; or
  • the reporting person has no relevant connection to our organization.

The whistleblower's motivation for making the report is irrelevant.

5. Through Which Channels Can Violations Be Reported?

Whistleblowers may report misconduct either internally within our organization or externally to the competent public authorities.

They are free to choose whether to submit reports covered by the German Whistleblower Protection Act through the internal or external reporting channel.

Information regarding relevant legal violations may only be disclosed directly to the public (for example through the media) under exceptional circumstances. Further details are provided under "Public Disclosure of Information."

6. Persons Responsible for the Internal Reporting Office and Their Responsibilities

The following trusted person has been appointed as the person responsible for the internal reporting office for SnowWorld Bispingen:

Hüseyin Acikgöz

The internal reporting office:

  • acknowledges receipt of reports;
  • assesses whether the report falls within the scope of the Whistleblower Protection Act;
  • examines whether the report appears well-founded;
  • investigates and evaluates the reported facts;
  • takes appropriate follow-up measures where necessary; and
  • maintains contact with the whistleblower whenever possible and provides feedback.

Upon request, the internal reporting office will arrange a personal meeting with one of the designated trusted persons.

Confidentiality

Strict confidentiality applies.

Personal information, including the identity of whistleblowers or any information that could reveal their identity, may only be disclosed to persons who are responsible for receiving reports, taking follow-up measures, or assisting with those duties, unless the whistleblower has expressly consented to disclosure.

Confidentiality does not apply where the reporting person knowingly or with gross negligence submits false information.

Reported information may also be disclosed to competent authorities where required, for example during criminal investigations or pursuant to a court order.

The identity of the person(s) concerned by a report is likewise treated confidentially and disclosed only where necessary to investigate the reported facts.

To ensure independence, the persons responsible for the internal reporting office act independently and are not bound by instructions from the management in matters relating to whistleblowing.

Reports can be submitted to SnowWorld Bispingen through the following channels:

  • Telephone: Normally between 9:00 a.m. and 4:00 p.m., Monday to Friday, on +49 (0)2131 1244101. Outside these hours, a voicemail service is available.
  • Post:
    Attn. Trusted Person
    An der Skihalle 1
    41472 Neuss
    Germany
  • E-mail: hueseyin.acikgoez@snowworld.com (mailto:hueseyin.acikgoez@snowworld.com)

Other internal reporting channels and complaint procedures remain unaffected by this policy. Individuals remain free to choose the reporting channel they consider appropriate.

7. External Reporting Channels

Whistleblowers may also submit reports to public prosecutors, the authorities designated under Chapter 2, Subchapter 3 of the German Whistleblower Protection Act, or any other competent authority responsible for the relevant legal violation.

8. Public Disclosure of Information

Public disclosure of information (for example through the media, the press, or social media) is protected if the whistleblower has first submitted an external report but did not receive a timely response or appropriate follow-up action.

Whistleblowers may also publicly disclose information where they reasonably believe that:

  • there is an immediate or obvious danger to the public interest, such as an emergency or the risk of irreversible harm;
  • they are likely to face retaliation;
  • evidence may be concealed or destroyed;
  • there may be collusion between the external reporting authority and the person responsible for the violation; or
  • other exceptional circumstances make it unlikely that the external reporting authority will take effective follow-up action.

9. What Happens After a Report Is Submitted to the Internal Reporting Office?

The internal reporting office:

  • acknowledges receipt of the report within seven days, provided contact details are available;
  • assesses the report and determines whether the reported violation can be investigated and whether the information appears credible;
  • discusses the matter with the whistleblower where appropriate and determines the necessary investigative and follow-up measures;
  • provides feedback no later than three months after acknowledging receipt of the report, or, where no acknowledgement was issued, within three months and seven days after submission, provided contact details are available.

The feedback includes information about planned or already implemented follow-up measures together with the reasons for those measures.

Feedback will only be provided where doing so does not interfere with internal investigations or infringe upon the rights of individuals who are the subject of, or mentioned in, the report.

10. Prohibition of Disadvantages or Retaliation

No person making a protected whistleblower report may suffer retaliation.

Retaliation includes, but is not limited to:

  • suspension;
  • dismissal;
  • negative performance evaluations;
  • claims for damages;
  • salary reductions;
  • disciplinary measures;
  • failure to convert a fixed-term contract into a permanent contract; or
  • any similar disadvantageous treatment.

Where such measures are taken against a whistleblower in connection with a protected report, German law presumes that the measure constitutes unlawful retaliation.

Bispingen, October 2025

Act on Better Protection of Persons Reporting Violations (German Whistleblower Protection Act – Hinweisgeberschutzgesetz (HinSchG))