Implementation of the Whistleblower Protection Act at the ZZF
The Whistleblower Protection Act (Hinweisgeberschutzgesetz, or HinSchG) came into force in Germany in 2023 and implements the EU Whistleblower Directive (Directive (EU) 2019/1937) into German law. The HinSchG expands the previously incomplete and inadequate protection of whistleblowers in order to strengthen their protection.
If there is a suspicion of non-compliant behaviour at the ZZF and it is not possible to speak to trusted persons at the ZZF to dispel the suspicion, a report can be made via an anonymous reporting channel. The report will be sent to the law firm FPS Fritz Wicke Seelig, Berlin, with whom the ZZF and the Leibniz Association have concluded a contract.
Who can submit a report?
All employees at the ZZF and all persons associated with our work can use this reporting channel to anonymously, quickly and securely report possible violations of certain laws or regulations.
What can be reported?
The possible violations that can be reported via this procedure relate to violations of legal regulations on the award of public contracts, incidents of money laundering and terrorist financing, violations in the areas of environmental protection, data protection and data security, violations of the Financial Services Supervision Act and tax law and similar. Reasonable suspicions or information about actual or potential violations as well as attempts to conceal such violations that have already been committed or are very likely to occur can be reported.
How can a report be submitted?
Reports can be submitted to the law firm via the following channels:
- Via the link on the website: zzf.whistlelink.com
- By telephone via the authorised law firm: 030-885927-582 (Ms Johnson or Ms Petersen) or 030-885927-0 (switchboard with answering machine outside office hours)
- Via persons of trust at the ZZF such as the Works Council, ombudsperson for scholarship, equal opportunities officer or data protection officer
Are there other reporting centres?
Whistleblowers can also contact an external official reporting centre such as the Federal Office of Justice directly via the following link: External federal reporting centre.
How is confidentiality/anonymity guaranteed?
In order to guarantee anonymity and confidentiality, the ZZF works together with the Berlin law firm FPS, which was awarded the contract in the Leibniz Association’s tendering process to establish a reporting system at the Leibniz Institutes. An IT-supported platform (“reporting channel”) enables reports to be submitted both confidentially and anonymously.
What happens with a report?
Once a report has been submitted, the following steps are initiated:
- The whistleblower will receive confirmation from the law firm that the report has been received within seven days at the latest (Section 17 (1) HinSchG).
- It will be checked whether the report fits within the material scope of application (Section 2 HinSchG) and whether the reported offence is valid.
- If necessary, the whistleblower will be asked for further information.
- If the case is relevant to an audit, appropriate follow-up measures will be initiated (depending on the report, these may include further internal investigations and discussions or referral to another competent body).
- The whistleblowers receive feedback on the follow-up measures that have been taken or are planned, as well as the reasons for them - after three months at the latest (Section 17 (2) HinSchG).