1. Introduction

Whistleblowing is ‘making a disclosure in the public interest’ and occurs when a member of staff and/or stakeholders raises a concern about danger, impropriety or illegality that affects others, for example colleagues or members of the public.

The MRS Group is committed to the highest possible standards of openness, probity and accountability. In line with that commitment the MRS Group expects staff, and others that we deal with, who have serious concerns about any aspect of the MRS Group's work to come forward and voice those concerns. It is recognized that most cases will need to proceed on a confidential basis.

Staff might be the first to realize if there is something seriously wrong within the MRS Group. However, they might not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the MRS Group. They might also fear harassment or victimization. In these circumstances, it may be easier to ignore the concern rather than report what may merely be a suspicion of malpractice.

This Whistle-blowing Policy makes it clear that a member of staff can do so without fear of victimization, subsequent discrimination, or disadvantage. It is intended to encourage and enable staff to raise serious concerns within the MRS Group rather than overlooking a problem or 'blowing the whistle' outside.

The policy applies to all MRS Group staff including, for example, secondees, contractors and agency workers working for the MRS Group.


2.  Aims and scope of this policy

This policy applies to whistleblowers. Whistleblowers are reporting persons who acquired information on breaches in a work-related context.

This includes, but is not limited to, our current and previous employees, self-employed persons, shareholders, and persons belonging to MRS Group management or supervisory body of our company, including their non-executive members, as well as volunteers, paid or unpaid trainees, clients, customers, and any persons working under the supervision and direction of our joint venture partners, contractors, subcontractors and suppliers.

This policy shall also apply to whistleblowers whose work-based relationship is yet to begin in cases where information on breaches has been acquired during the recruitment process or other pre-contractual negotiations.

Protection under this policy shall also be provided to persons assisting whistleblowers in the reporting process (facilitators), third persons who are connected with the whistleblower (colleagues or relatives) and who could suffer retaliation in a work-related context, and legal entities that the whistleblower owns, works for or is otherwise connected with in a work-related context.

We hereby comply with legal requirements set by Directive (EU) 2019/1937 and implemented in national law Hinweisgeberschutzgesetz (HinSchG) from July 2nd, 2023.

The internal reporting channel is intended for reports, where a whistleblower has at least reasonable suspicion about actual or potential breaches, which occurred, are currently ongoing, or are very likely to occur, and about attempts to conceal such breaches.

A breach is any act or omission that is unlawful and relates to MRS Group, or defeats the object or the purpose of legislation, our policies and/or internal regulations. A breach can include, but is not limited to, the following:

  • bribery or corruption
  • fraud, money laundering, theft or improper use of company property or funds,
  • undeclared or mismanaged conflicts of interest,
  • anti-competitive behavior,
  • insider trading or market abuse,
  • breach of sanctions,
  • financial irregularities,
  • data privacy violations,
  • gross negligence, bullying, unlawful discrimination, workplace, or sexual harassment,
  • gross waste or mismanagement,
  • unsafe work practices and other significant safety or health concerns,
  • modern slavery and human rights breaches,
  • significant harm to the environment,
  • retaliation against a whistleblower or other protected person under this policy and,
  • any other conduct which is unethical, in breach of MRS Group policies or procedures, or illegal or unlawful.

The internal reporting channel is not intended for submitting complaints, warranty claims etc. Such reports will not be processed under this policy. For addressing latter issues, please refer to your known contact within the MRS Group.


3. How to raise a concern

The authorized staff (details see below) is available to provide support or advice on MRS Group’s whistleblowing process.

Reports can be submitted by using MRS Group’s online whistleblowing solution “Trusty” available under


4. Confidentiality and content

A report should include as much details as possible on who, what, where, when, how and why in relation to the reported breach, as well as any evidence in support thereof. Any other information as to how MRS Group might best go about processing the reported breach are also welcome.

Whistleblowers may submit reports anonymously or may choose to disclose their identity. The Whistleblowing software allows for a two-way anonymous communication even if a whistleblower chooses to report a breach without disclosing his or her identity. Whistleblowers are encouraged to identify themselves. This allows for a more productive and efficient processing of their reports and their protection against retaliation.

The whistleblowers’ identities, as well as any other information from which their identities may be directly or indirectly deduced, shall not be disclosed to anyone beyond the authorized staff members competent to receive and follow up on reports, without whistleblowers’ explicit consents.

Notwithstanding the preceding provision, MRS Group shall disclose a whistleblower’s identity when required to do so by law, whereby it shall inform the whistleblower thereof before such disclosure, unless such information would jeopardize the related investigations or judicial proceedings.

Any unauthorized attempts to identify a whistleblower or a concerned person are not allowed and shall be disciplinarily sanctioned.


5. How the MRS Group will respond

MRS Group’s internal reporting channel is operated by the respective compliance department. who is authorized to receive and follow up on reports (authorized staff).

The authorized staff has direct, unrestricted, and confidential access to MRS Group’s governing body and top management to which it directly reports on the performance of the whistleblowing management system. The authorized staff has direct, unrestricted access to adequate resources as necessary to ensure the impartiality, integrity and transparency of the whistleblowing management system and its processes.

Processing of a report is conducted in the following steps, depending on the content of the report and its nature:

  • received – the report has been received by MRS Group;
  • initial triage – the content of the report is being assessed for the purposes of categorization (Whistleblowing case, Non-Whistleblowing case but miscellaneous compliance, Non-Whistleblowing case), taking preliminary measures, prioritization and assignment for further handling;
  • processed – the report is being handled, accuracy of the allegation is being assessed, internal enquiry or action for
    recovery of funds is being conducted;
  • in investigation – the allegation is being investigated;
  • closed – the processing of the report has been completed; either no action is considered necessary in response to a report, fact-finding determines no further investigation is warranted, the report is referred to another process to be dealt with, or the investigation has been completed (whether or not breach is confirmed).

MRS Group aims to process the reports in a timely manner. Circumstances such as the complexity of the reported breach, competing priorities and other compelling reasons may require an extended period for the completion of the processing of the report.

MRS Group processes the reports confidentially, impartially, and without bias or prejudice against the whistleblower or any other person involved in, or any witness to, the reported breach.

The persons concerned, i.e. the persons referred to in the reports, shall enjoy the presumption of innocence. They may be notified of the respective reports at an appropriate time. Any investigation shall be conducted in a manner that preserves confidentiality to the extent possible and appropriate to ensure that the persons concerned are not exposed to reputational harm (information is shared on a strictly need-to-know basis).

After submitting a report, the whistleblower shall receive a receipt acknowledgment forthwith and no later than within seven days of that receipt.

The receipt acknowledgment is sent to the email address which is provided by the whistleblower during the online report submission process. The confirmation of the receipt of the report is also provided in the whistleblower’s inbox which is accessible online under the reporting channels using the log-in credentials which are provided to the whistleblower upon the completion of the report submission process. The latter are provided also to anonymous whistleblowers.

The authorized staff maintains communication with the whistleblower and, where necessary, asks for further information or evidence from and provide feedback to the whistleblower. The said communication is conducted through the whistleblower’s inbox, or through other communication channels agreed with the whistleblower.

The feedback to the whistleblower is provided no later than 3 months from submitting the report. The feedback includes information on the action envisaged or taken as follow-up and on the grounds for such follow-up. The feedback can be limited to avoid compromising any investigation or other legal proceedings, as well as due to legal restrictions on what can be communicated about the follow-up and findings. In such a case and where possible, the whistleblower shall be notified of the reasons of the limited feedback communication.

MRS Group may decide to acknowledge and give recognition to the whistleblower for reporting a breach, with prior consent of the whistleblower (including, but not limited to, expressing gratitude and public commendation by the top management).

If a reported breach is not substantiated by the authorized staff and the respective data are not required by MRS Group for any further proceedings, the report and all the gathered information related to the report and its processing shall be permanently deleted 7 years after closing the case.

If a reported breach is substantiated, the report and all the gathered information related to the report and its processing shall be stored for as long as necessary for the assertion and exercise of, or defense against respective legal claims.


6. Retaliation and protection against it

If an investigation finds that a staff member of an MRS Group has committed an act of retaliation, s/he shall be subject to disciplinary proceedings. The MRS Group shall also consider adopting any other measures necessary to remedy the retaliation.

If an investigation finds that an external party to an MRS Group has committed an act of retaliation, then the MRS Group shall review any business with such party and undertake appropriate action. Actions may include, but are not limited to, terminating business with such a party, refraining from future business with such a party, or exercising contractual remedies, if applicable, as well as pursuing available judicial remedies.

Whistleblowers, persons who have supported a Whistleblower or persons associated with a Whistleblower who believe that they have been victims of retaliation or have valid reasons to believe that they are exposed to a risk of retaliation, should immediately report the matter to the authorized staff. If the alleged retaliator is the authorized staff, the report shall be made to the top management.

A person who submits a complaint of retaliation must establish the respective facts with information or documentation in support of his/her complaint. A complaint of retaliation shall be treated as strictly confidential and will not interfere with the investigation of the primary allegation of misconduct unless the retaliation constitutes a form of obstruction or an attempt of obstruction.

It shall be up to the individual who has allegedly committed the retaliation act to prove that there is no causal link between the whistleblowing report and the alleged retaliation act, i.e. that the act is not a retaliation against the Whistleblower.

Based on the reported retaliation, the authorized staff shall assess the matter without undue delay and may launch an inquiry.

Whistleblowers shall not lose protection if their reports cannot be substantiated.

Where a Whistleblower, a person who has supported a Whistleblower or a person associated with a Whistleblower reasonably believes s/he is threatened with retaliation or retaliated against because s/he reported information, the authorized staff shall provide appropriate assistance to secure his/her protection. Should the retaliation or the threatened retaliation come from the authorized staff, the top management shall provide appropriate assistance to secure the Whistleblower’s protection.

The authorized staff shall assess the circumstances of the case and may recommend to the top management, that temporary and/or permanent measures be adopted to protect the Whistleblower, a person who has supported a Whistleblower or a person associated with a Whistleblower and after consulting him/her/them. Such measures might include, but are not limited to:

  • the temporary suspension of the effect of actions alleged to be retaliatory until their verification;
  • mobility: temporary and/or permanent reassignment of the Whistleblower, of the person who has supported a Whistleblower, of the person associated with a Whistleblower or of the retaliating staff member to another position, if appropriate and to the extent possible, taking into consideration the types of posts that fit their profiles and the needs of the services;
  • placement on paid administrative leave of the Whistleblower, of the person who has supported a Whistleblower, of the person associated with a Whistleblower or of the retaliating staff member for an initial period. The top management may approve an extension of such leave for the period necessary to complete the investigation;
  • transfer of the manager’s responsibility for the performance management of the Whistleblower or the person who has supported a Whistleblower, or the person associated with a Whistleblower;
  • any other actions deemed appropriate to mitigate the possibility of retaliation and consequences of retaliation.

The Whistleblower, the person who has supported a Whistleblower or the person associated with a Whistleblower shall be informed in writing of the results of the measures to be adopted.


7. Protection of the person concerned

Notwithstanding the safeguards provided for in the applicable investigation procedures, persons concerned shall enjoy the presumption of innocence and the right of defense.

The identity of the persons concerned shall be disclosed only to those persons or entities authorized to receive them or otherwise, on a strict need-to-know basis.

Upon dismissal of the case, persons concerned shall have the right to seek an effective remedy, including their appropriate reinstatement in service.


8. Disciplinary proceedings

Any infringement of any of the provisions of this Policy may constitute misconduct and lead to disciplinary proceedings.

Abusive, false, or malicious allegations, particularly if they are based knowingly on false or misleading information may also lead to disciplinary and criminal proceedings, as applicable.