Dear whistleblower,

The Raiffeisen Waren Group takes its responsibility for ensuring lawful and compliant conduct (“Compliance”) by all its employees – from student assistants to executive management – extremely seriously. Each employee contributes through their personal integrity and behaviour to the good reputation of our company, the trust of our business partners and customers, the well-being of all employees, and the sustainable economic success of the Raiffeisen Waren Group.

Early detection and clarification of potential compliance violations are essential to ensure that misconduct can be corrected immediately and that the compliance management system can be adapted where necessary. This requires the attention of all employees and their willingness to report potential concerns or suspected irregularities.

In accordance with the requirements of the German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG)*, the Raiffeisen Waren Group provides a modern whistleblowing and complaints procedure. This system offers confidential and technically secure communication channels for (anonymous) reports and ensures transparent, prompt, and objective investigation. We therefore encourage all employees of the Raiffeisen Waren Group to report potential grievances or irregularities through this procedure in accordance with these procedural rules.

Naturally, the whistleblower/complaints procedure is also available to customers, business partners, third-party providers, and any other individuals who intend to report practices, conduct, or circumstances that raise concerns regarding legal or compliance violations.

In addition, the whistleblower/complaints procedure also serves to clarify indications of human-rights-related or environmental risks or violations arising from the economic activities of the Raiffeisen Waren Group, either within its own operations or within the operations of its direct or indirect suppliers. The system therefore also functions as a complaints mechanism within the meaning of the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG)** for whistleblowers along the supply chain.

We trust that this procedure will be used responsibly. It is not intended as a personal “complaints box”.

In consideration of the above, it is important to us to describe in detail how to use our whistleblower/complaints procedure.

NOTE: This whistleblower/complaints procedure applies to the companies of the Raiffeisen Waren Group listed here.

I. Available Reporting Channels

You may submit hints and complaints to our internal reporting office via several channels (telephone, mail, or online). Upon express request, our internal reporting office is also available for personal appointments.

1. Personal reporting

To arrange a personal appointment, please contact our internal reporting office first via one of the reporting channels listed below.

2. Reporting by telephone

For telephone reporting of hints or complaints, or for any questions regarding the whistleblower/complaints procedure, our internal reporting office is available Monday to Friday between 08:00 and 16:00 at:

+49 (0) 561 7122-610

If your hint or complaint concerns one of our in-house legal professionals, you may alternatively contact our data protection coordinator at:

+49 (0) 561 7122-315

3. Reporting by mail

Postal address for written reports:

Raiffeisen Waren GmbH
Legal Department
Ständeplatz 1–3
34117 Kassel
Germany

If you do not wish our secretarial staff to become aware of your report, you may address your letter directly to our internal reporting office with the note:
“confidential / to be opened only by the internal reporting office”.

For convenience, you may use our whistleblower/complaint form. It is available in the respective branches or downloadable here.

If you have submitted your report with your contact details, you will receive an acknowledgment of receipt within one week after we receive your report.

4. Online reporting

a. Technical introduction

Our online reporting system is operated using the “Trusty” platform provided by Trusty AG. You will be guided through the reporting process in only a few steps, without any registration required. The process includes the following steps:

1. Open our reporting system at
   rw.trusty.report
   and click on “Create Report”.
2. Read the information on security and confidentiality, data processing provisions, and anonymity obligations. Confirm your acceptance by checking the designated box, then click “Next”.
   The mentioned information can be accessed by clicking “Information” above the checkbox or “Data Protection” at the bottom of the page.
3. Select the country in which the violation occurred from the drop-down list, then click “Next”.
4. Enter the location and time of the violation, the people involved, and a description of the incident to the best of your knowledge. If available, you may attach additional relevant documents by clicking “Attach documents”. Then click “Next”.
5. Choose whether you wish to submit your report anonymously or with personal details. Click “Next” to enter your personal information, or “Submit” directly if reporting anonymously.

Our privacy policy for the whistleblower system can be accessed here.

II. Procedure After Receipt of the Report

1. Acknowledgement of Receipt and Documentation

As already explained, you will receive confirmation of receipt no later than seven days after your report has been received, unless this is impossible due to a lack of available contact details.

All incoming reports are documented in a permanently retrievable form while strictly observing confidentiality requirements. Documentation is generally deleted three years after the conclusion of the procedure, unless longer retention is legally required and proportionate.

If you request a personal meeting with the internal reporting office, or in the case of a telephone report, the conversation will – with your consent – be documented either through an audio recording (e.g., via dictation device) or through a detailed written record of the conversation. This transcript will then be provided to you for review, signature, and any comments or corrections. If an audio recording was used, it will be deleted once the transcript has been prepared.

If you do not agree to the creation of an audio recording or a verbatim transcript, the report will be documented by means of a content summary prepared by the internal reporting office.

2. Initial Review and Fact-Finding

Within one to four weeks following receipt of your report or complaint, the internal reporting office will perform an initial review and, where necessary, initiate fact-finding measures.

During this stage, the plausibility of your report is assessed, and it is examined whether the reported risk or violation falls within the scope of our whistleblower/complaints procedure. It is also assessed whether sufficient factual indications exist to justify further investigation. Please understand that the time required for this step may vary depending on the detail of the information you have provided and the nature of the reported risk or violation.

Please note that persons named or identified during this stage may already be questioned regarding the incident. If further information is required, we will contact you—where possible.

Once the preliminary investigation is completed, you will receive an interim status update. Regardless of this, you may submit questions regarding your report to us at any time.

3. Completion of the Investigation

The investigation is considered complete when:

– sufficient information is available to reliably determine that the reported (potential) violation or risk did not occur, or
– sufficient information is available to reliably determine that the reported (potential) violation or risk has occurred, or
– further fact-finding is not possible or would be disproportionate with reasonable means.

After completion of the investigation, the internal reporting office prepares a written investigation report, containing:

– a description of the established facts, and
– the justified investigation outcome.

If the suspicion is confirmed, it will be assessed—possibly together with the HR department—which measures are appropriate in the specific case, either within the company or against employees or suppliers. Depending on the circumstances, this may include personnel-related, employment-related, liability-related, or contractual measures. Additionally, reporting to authorities or the public prosecutor's office may be required.

In all cases, we will take appropriate measures within our capabilities to prevent, minimise, or ideally eliminate the identified risk or violation. The investigation report will include a corresponding justified recommendation.

Depending on the nature and severity of the reported risk or violation, the investigation may take up to twelve months. To maintain your trust in our whistleblowing process, we will provide regular updates—at least quarterly—including information on:

– the current status of the investigation,
– planned and implemented follow-up measures, and
– reasons for selecting those measures.

Please note, however, that updates may only be provided to the extent that internal investigations or the rights of persons named in the report are not compromised.

After the investigation is completed, you will receive a final notification.

4. Notification of Executive Management

The internal reporting office will inform the management of the Raiffeisen Waren Group company concerned no later than upon completion of the investigation, unless earlier notification is required based on the content of the report or the findings.

The identity of the whistleblower will not be disclosed to management.

In the event of a conflict of interest, the report will only be submitted to the managing directors not affected by the conflict. If all managing directors are affected, the report will be directed to the chairperson of the relevant supervisory body, or alternatively its members (e.g., Supervisory Board Chair or shareholders).

5. Evaluation of Measures Taken

To evaluate the measures implemented, ensure process optimisation, and verify that you do not experience any retaliation afterward, we will—where possible—contact you again after conclusion of the procedure. This usually occurs within twelve months after completion.

If you do not wish to be contacted for evaluation, please let us know.

6. Feedback Survey

To ensure that our whistleblower/complaints procedure continues to meet the needs of whistleblowers, we may request your feedback after the conclusion of the process.
If you prefer not to participate, simply let us know.

7. Entry into Force and Regular Review

These procedural rules, including the following “FAQ”, replace the previous rules and enter into force on 01 December 2023.
They will be reviewed annually and additionally whenever necessary for accuracy, effectiveness, and relevance.