Whistleblower Policy

Purpose

Sternberg Consulting is committed to conducting business with integrity. This Whistleblower Policy provides a safe, confidential mechanism for staff, subcontractors, clients, and third parties to raise concerns about potential misconduct, legal violations, or ethical issues — including modern slavery and human trafficking risks — without fear of retaliation.

What Can Be Reported

You may use this procedure to report concerns about:

  • Modern slavery, forced labour, or human trafficking
  • Bribery, corruption, or fraud
  • Violation of laws, regulations, or company policies
  • Health and safety violations
  • Environmental misconduct
  • Harassment, discrimination, or serious workplace misconduct
  • Any other serious ethical concern

How to Report

Concerns can be raised through the following channel:

Reports may be submitted anonymously. Where contact details are provided, we will acknowledge receipt within 5 business days.

Protections for Reporters

Sternberg Consulting strictly prohibits retaliation against anyone who raises a concern in good faith. This includes:

  • Dismissal or disciplinary action
  • Demotion or disadvantage
  • Harassment or victimisation

If you believe you have been subjected to retaliation, please contact us immediately.

Investigation Process

All reports will be:

  • Treated as confidential
  • Assessed and investigated by a designated responsible person
  • Responded to within a reasonable timeframe
  • Escalated to external authorities if required by law

We will not disclose the identity of the reporter without consent, except where required by law.

External Reporting

In addition to our internal channels, individuals may also report concerns to relevant external bodies, including the relevant national authorities in Germany or other applicable jurisdictions.

Review

This policy is reviewed annually by the management of Sternberg Consulting. Last reviewed: March 2026.

Contact: info@sternberg-consulting.com