Guidance for whistleblowers at SnowWorld Neuss
This guide describes how we aim to facilitate whistleblowing at SnowWorld Neuss.
Version: January 2026
Table of Contents
- What is a whistleblower?
- What can whistleblowers report at SnowWorld Neuss?
- Who can be a whistleblower at SnowWorld Neuss?
- 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 Neuss?
- Prohibition of disadvantages or retaliation
We are convinced that whistleblowers play an important role in supporting democracy and the rule of law. It is our belief that reporting legal violations and serious misconduct should not be punished or result in any other disadvantage for the reporting individual. We therefore advocate for stronger legal protection for whistleblowers and seek to uphold this principle within our own organization. This guide describes how we facilitate whistleblowing at SnowWorld Neuss.
1. What is a whistleblower?
A whistleblower is not a traitor. Rather, a whistleblower is a person who makes information of public importance known from a confidential or protected environment, such as in cases involving food safety scandals or misconduct within the healthcare system.
2. What can whistleblowers report at SnowWorld Neuss?
Whistleblowers may report violations in accordance with Section 2 of the German Whistleblower Protection Act (Hinweisgeberschutzgesetz). This includes, among other things, criminal offenses and administrative violations where the breached regulation serves to protect life, health, or the rights of employees or their representative bodies.
In addition, violations of specific federal and state regulations, as well as directly applicable legal acts of the European Union and the European Atomic Energy Community, may be reported. These may relate to areas such as environmental protection, personal data protection, privacy in electronic communications, or information security.
3. Who can be a whistleblower at SnowWorld Neuss?
The following individuals may act as whistleblowers:
- Employees
- Trainees
- Interns
- External service providers
Furthermore, individuals whose employment has not yet commenced may submit reports if they become aware of violations during the recruitment process or other pre-contractual negotiations. Former employees whose employment relationship has ended may also act as whistleblowers.
4. When are whistleblowers protected?
Whistleblowers are protected against retaliation only if they had reasonable grounds to believe that the information reported was true and that the reported violation falls within the scope of the Whistleblower Protection Act. This means they must act in good faith and without knowingly or grossly negligent misjudgment.
Protection does not apply if:
- The report is knowingly false or made with gross negligence.
- The information was already fully public knowledge.
- The report consists solely of speculation or rumors.
- The reporting individual has no relevant connection to our organization.
The whistleblower’s motivation is irrelevant to the protection provided.
5. Through which channels can violations be reported?
Whistleblowers may report misconduct either:
- Internally within our company, or
- Externally to government authorities.
They are free to choose whether to report violations covered by the Whistleblower Protection Act internally or externally.
However, information concerning relevant legal violations may only be disclosed directly to the general public (for example through the media) in exceptional circumstances (see “Public Disclosure of Information” below).
6. Persons responsible for our internal reporting office and their duties
The following trusted person has been appointed as the responsible officer for the internal reporting office at SnowWorld Neuss:
Hüseyin Acikgöz
The internal reporting office:
- Confirms receipt of reports.
- Assesses whether the report is protected under the Whistleblower Protection Act.
- Evaluates the credibility of the report.
- Investigates and assesses the reported facts.
- Takes follow-up measures where appropriate.
- Maintains contact with whistleblowers and provides feedback where possible.
Upon request, the internal reporting office can arrange a personal meeting with one of the designated trusted persons.
Confidentiality Requirement
Personal information, including the identity of whistleblowers or information that could reveal their identity, may only be disclosed to third parties with the whistleblower’s explicit consent, unless those persons are directly involved in receiving reports or carrying out follow-up measures.
The confidentiality obligation does not apply where the reporting person knowingly or grossly negligently provides false information. Reported information may also be shared with competent authorities, for example during criminal proceedings upon request by law enforcement agencies or pursuant to a court order.
The identity of accused persons will likewise be treated confidentially and disclosed only for purposes related to clarifying the facts of the case.
To ensure this, individuals assigned to the reporting office operate independently and are not bound by instructions from company management in these matters.
Reporting Channels
Reports can be submitted through the following channels:
- By telephone, generally between 9:00 a.m. and 4:00 p.m. from Monday to Friday, at +49 (0)2131 1244101. An answering machine is available outside these hours.
- By post, addressed to the trusted persons:
An der Skihalle 1, 41472 Neuss, Germany - By email: hinweis.neuss@snowworld.com
Other internal reporting channels and complaint procedures remain unaffected by this guide. Individuals remain free to choose the reporting route they prefer.
7. External Reporting Channels
Whistleblowers may also contact:
- Public prosecutors,
- Authorities designated under Chapter 2, Subchapter 3 of the German Whistleblower Protection Act,
- Other competent authorities responsible for the relevant legal violations.
8. Public Disclosure of Information
Disclosure of violations to the public (for example through media outlets, the press, or social media) may be protected if:
- The whistleblower previously reported the violation externally and did not receive a timely response, or
- No appropriate follow-up measures were taken.
Whistleblowers may also disclose information publicly if they reasonably believe that:
- There is an immediate or obvious threat to the public interest,
- Irreversible damage may occur,
- Retaliation is likely,
- Evidence may be concealed or destroyed,
- There may be collusion between the external reporting authority and the perpetrator,
- Or other special circumstances make effective action by the external reporting authority unlikely.
9. What happens after a report is submitted to the internal reporting office of SnowWorld Neuss?
The internal reporting office:
- Confirms receipt of the report within seven days, provided contact details are available.
- Reviews the report and assesses whether the alleged violation can be investigated and whether the information appears credible.
- Discusses the matter with the whistleblower where necessary.
- Determines appropriate investigative steps and any follow-up measures.
- Provides feedback within three months after confirming receipt of the report, or within three months and seven days if no confirmation was issued, provided contact details are available.
The feedback includes information about planned or completed follow-up measures and the reasons for them.
Feedback will only be provided where it does not interfere with internal investigations or infringe upon the rights of individuals who are the subject of the report or are named within it.
10. Prohibition of Disadvantages or Retaliation
No retaliatory measures may be taken against individuals who engage in protected whistleblowing. Prohibited measures include, but are not limited to:
- Suspension
- Dismissal
- Negative performance evaluations
- Claims for damages
- Salary reductions
- Disciplinary actions
- Failure to convert a fixed-term contract into a permanent contract
- Similar adverse measures
If such measures are taken against whistleblowers in connection with protected reporting activities, the law presumes that these actions constitute prohibited retaliation for the report.
Neuss, January 2026
Act for Better Protection of Whistleblowers (Whistleblower Protection Act – HinSchG)