Frequently asked questions

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Contacts


Robert Bosch OOO

Compliance Officer

Khimki, Vashutinskoe shosse, 24

Russia, 141400, Moscow region

Phone: +7 (495) 560-94-61

Content

1. What do we mean by compliance?

Compliance means observing laws and company regulations. In other words, all business activities of the Bosch Group and of its associates must comply with all legal requirements, the Code of Business Conduct, and any applicable guidelines and central directives that relate to this topic in any way (“compliance requirement”).

Compliance also relates to business relations between Bosch and third parties: Bosch does not want to be involved in other parties’ violations of the compliance requirement.

2. Who can report violations of the compliance principle?

In addition to the supervisors, each associate as well as any business partners of Bosch is asked to report possible violations of the Compliance requirement and thereby help to ensure that the consequences of such violations will be limited and a similar misconduct can be avoided in the future. This means that everybody may report:

  • Any associate, including interns and Ph.D. students
  • Externally employed persons such as subcontracted employees or associates working for external service providers
  • Any business partner, such as suppliers, customers, or joint venture partners
  • Any third party

3. How can I report a possible violation of the Compliance requirement?

Basically, violations of the Compliance requirement should be reported the contact person at Bosch or to his/her supervisor (administrative way). If you prefer not use the regular official channel, e.g. because you assume that the use of the regular official channel will not be effective or harmful for yourself, you can contact the relevant Compliance Officer either directly or via the Whistleblowing System.

4. What about the protection of my pers. data, if I report a violation of the Compliance requirement

For details, e.g. the processing of personal data and access to personal please refer to the data protection notice in the Whistleblowing System.

5. Do I have to mention my name when reporting a possible violation of the compliance requirement?

You can choose making a report without including your name (anonymous report). However, we would like to recommend that you disclose your identity. The information provided by you will be treated confidentially in any case.

Anonymous reports alone will not result in disadvantages for an associate. Additional, incriminating evidence is always needed. If evidence is found as a result of anonymous reports, the associate concerned must answer for the proven misconduct. But if there are no facts to back up the anonymous report, the matter will be treated as though it had never happened. There is no risk of any consequences for the accused associate. In particular, the issue will not be documented in his or her personnel file.

Moreover, anonymous reports are nothing new. The company has received anonymous reports in the past, and has had to follow them up. All that is new about this situation is that associates and third parties now have a defined reporting channel and, in the person of the compliance officer, a clearly defined contact person. From his position of neutrality, it is his responsibility to ensure that the situation is clarified rapidly and fairly.

6. What kind of violations should I report?

It is especially important that matters should be reported that appear to indicate a criminal offense – such as theft, fraud, or bribery – or a systematic violation of legal or company-internal regulations, such as the deliberate and sustained non-compliance with quality/safety standards or with the “Principles of Social Responsibility”.

7. A suspicion, but no proof - enough for a report?

Whoever makes a report must carefully consider the following two criteria before doing so:

  • Are there serious signs of wrongful behavior?
  • Do these signs justify investigating an associate or Bosch business partner who may in fact be acting legally?

Conducting investigations, gathering evidence that will stand up in court, and instituting any proceedings that may be necessary is the responsibility of the compliance officers. They receive support from experts in the specialist departments who have the necessary training and powers.

8. Threaten me disadvantages because of reporting a possible violation of Compliance principle?

Persons who report possible compliance issues to the best of their knowledge and in good faith do not have to fear any harassment by the company as a result of the report.

If it is clear that the Whistleblowing System has been misused, i.e. if matters are reported that are so obviously without foundation that they do not require serious investigation, Bosch reserves the right to take legal or disciplinary action against the person making the report.

9. What exactly happens to my report?

The Compliance Officer is responsible for having the matters reported to him investigated and properly settled (if necessary with the support of Bosch specialist departments or external specialists). If necessary, he initiates any steps that may be needed.

If the case is one of special significance, e.g. if members of senior management are involved, or if there is a risk of considerable damage to the Bosch Group, either financially or image-wise, the Central Compliance Department will also be alerted immediately. The Central Compliance Department coordinates global observation of the compliance requirement in the Bosch Group.

10. Documentation and transparency

Every report, and the measures taken, must be documented by the Compliance Officer. Once due consideration has been given to the justified interests of the parties involved, the person reporting the matter may inquire about the status of the investigations. If the investigation of a matter is dropped due to lack of sufficient evidence, the person accused will be informed accordingly, provided he was asked to comment in the course of the investigation or requested such information.