Whistleblower Protection

Whistleblower Protection

We at GLS are committed to clear ethical principles. This is a pillar of our success as a business. All GLS staff bears responsibility for GLS living up to its principles; quite often, it is the misconduct of just a few that badly reflects on the reputation of a business as a whole. Hence, it is crucial for GLS to get notified of potential misconduct of its staff, its suppliers or third parties as early as possible so that we can quickly act on it and efficiently remedy the situation.

Effective 1 January 2023, the Protected Disclosures Act, 2014 was updated as the Protected Disclosures (Amendment) Act, 2022 which transposes the EU Whistleblowing Directive into Irish Law. This Act obliges GLS to establish an internal reporting channel. Through this internal reporting channel, whistleblowers can inform GLS of potential work-related misconduct. Whistleblowers may use the internal reporting channel to report the following:

• Information on suspected criminal offences;
• Information about other violations as defined in the Protected Disclosures (Amendment) Act, 2022
• Information on suspected administrative offences insofar as the relevant provisions are aimed at the protection of life, physical integrity or health or the rights of workers or the rights of those representing workers (such as members of the works council);

Reports which concern the offences detailed above will be treated with the utmost confidentiality to maximize the protection of whistleblowers and those mentioned in the report. In addition, the Act protects whistleblowers against any form of retaliation.

For all other reports please feel free to also contact the internal reporting channel. Such reports are also treated strictly confidentially.

However, please be advised that, as a whistleblower, you will only enjoy the protections guaranteed by the Act if you had at the time of submitting the report sufficient reason to assume that your report was true. You are not protected when submitting a report which you know is untrue.

The internal reporting channel within the meaning of Section 9 of the Protected Disclosures (Amendment) Act,2022, is Compliance.

Please contact the internal reporting channel via 1) EQS or 2) our ombudsman Dr. Rainer Buchert:

1. EQS Integrity Line:

To the reporting channel

2. Dr. Rainer Buchert, Attorney-at-Law, Kaiserstraße 22, D-60311 Frankfurt am Main

Dr. Buchert can be reached as follows:

• Tel.: +49 69 710 33 330 or +49 6105-921355
• Fax: +49 69 710 34 444
• E-Mail: kanzlei@dr-buchert.de

Please feel free to use the electronic contact form also:

To the contact form

Besides contacting the internal reporting channel, you also have the possibility to contact the relevant authorities directly (external reporting). The relevant authorities are:

• Disclosure to a Prescribed Person- Prescribed persons have regulatory functions in the area which are the subject of the allegations. Examples are the Central Bank, The Health and Safety Authority and the Data Protection Commission. You can get a full list of prescribed persons by sector on gov.ie . This list will help you find the right person or body to report to.
• Office of the Protected Disclosures Commissioner
• Please follow this link for more information: Make a protected disclosure (whistleblowing) (www.gov.ie)

The Act allows you to choose whether you would like to contact the internal reporting channel first or whether you prefer to submit your report directly tothe relevant external authority. However, we urge you to always contact us first via the internal reporting channel.GLS will investigate your report with the utmost seriousness and will try to remedy the offence. If you are still dissatisfied with the situation following the completion of our internal follow-up measures, you may still contact the external authorities.