Internal message channels
HHLA has established procedures that allow employees to raise concerns and lodge complaints so that HHLA can respond appropriately to adverse effects and take remedial action.
If there are concrete suspicions of adverse effects, an investigation is undertaken and, if necessary, remedial action and subsequent mitigation actions are taken immediately. Where legally permissible, particularly with due regard to privacy, whistleblowers receive feedback on the actions planned or already taken within a reasonable period of time but no later than after three months or six months in exceptional cases. In doing so, HHLA satisfies the requirements set out in the German Whistleblower Protection Act (Hinweisgeberschutzgesetz). The effectiveness of any remedial actions is reviewed on a case-by-case basis and actions are not subject to a standardised procedure.
If an investigation finds that there is insufficient initial evidence, the proceedings are discontinued and the whistleblower is duly notified.
There are different internal channels available for employees to bring problems, concerns and needs to the company’s attention and have them reviewed:
Approaching their own manager
Reporting the matter to HR
Reporting the matter to the responsible occupational safety specialist within the Occupational Health and Safety Management staff department
Submitting the matter to the company suggestions scheme (Commission for Suggestions for Improvement, not at foreign locations)
Reporting the matter to the Complaints Office pursuant to the German General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz) (not at foreign locations)
In companies with co-determination structures, reporting the matter to the works council, the representatives for young people and trainees or the representative body for disabled persons
Reporting the matter to the Diversity and Inclusion staff department
Reporting the matter to the compliance officer/hotline
Reporting the matter to the company social counselling service (available in Hamburg)
In 2024, HHLA also launched a digital whistleblower system across the Group, which is available in various languages. It meets maximum privacy and data security standards and allows all employees to report any concerns or statutory violations, either anonymously or with contact details.
Moreover, each company has a compliance officer or compliance contact who employees may contact if they have any questions. HHLA employees can also contact external bodies, such as employment or occupational health and safety supervisory authorities, courts or trade unions in their specific country.
Complaints received through the aforementioned channels or contact persons are forwarded, if necessary, to the relevant departments (such as Human Resources) and dealt with on a case-by-case basis. At companies with employee representation, the relevant representatives are involved in clarifying the matter and taking remedial action as necessary.
All reports submitted via the whistleblower system are processed centrally by HHLA’s Compliance Department and/or by local compliance officers. They review the issue reported and obtain any further clarification regarding the case, if needed.
If contact details are provided, receipt of the report is confirmed within seven days. Whistleblowers also have the opportunity to provide additional information on the matter as the investigation progresses and to contact the Compliance department to discuss the matter with them.
Reports of violations and any confirmed violations are forwarded to the Executive Board member responsible on a quarterly basis as part of the compliance reporting process. Ad hoc reports are compiled in cases involving significant violations.
The digital whistleblower system, like the other reporting channels, can be accessed via the HHLA intranet and the internet. All reporting channels are communicated to employees through both online and in-person trainings, as well as via targeted distribution of flyers and other informational materials.
In HHLA’s opinion, the fact that reports are regularly received via the whistleblower system and that it is actively used serves as testimony to the system’s effectiveness. Furthermore, no cases have been brought to the attention of the compliance officers to date that would indicate vulnerability to errors.
In accordance with the Whistleblower Protection Act, HHLA’s whistleblower system enables anonymous communication via a secure mailbox, protecting whistleblowers from retaliation. Employees of HHLA’s Compliance department are also obliged to treat all reports as confidential and to act impartially.
As employees use the established reporting channels on a regular basis, the company assumes that they trust the system and will continue to use it actively. This assessment is supported, in particular, by the low thresholds for accessibility and the option of anonymous reporting on the portal.