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Rhine-Waal University of Applied Sciences (HSRW) is committed to effective compliance. Compliance means adhering to the law and to the university’s internal rules, and establishing structures to ensure that the university management and all its staff can act in accordance with the law.
In this context, HSRW has set up a reporting channel in accordance with the Whistleblower Protection Act (HinSchG): via the ISO 27001-certified whistleblower system www.safewhistle.info, Dr Johannes Dilling, a solicitor, acts as an independent compliance ombudsperson (‘ombudsperson’) to receive your reports.
In accordance with Section 1(1) of the HinSchG, the whistleblowing system is open to any person who, in connection with their professional activities or in the run-up to such activities, has obtained information about breaches and wishes to report or disclose this information.
Frequently Asked Questions
The following section answers some frequently asked questions. For further information, please visit www.safewhistle.info.
Your reports help us to address breaches of applicable law or HSRW’s internal guidelines at an early stage and to prevent harm to our staff, business partners, third parties and the university as a whole. For this reason, the HSRW has appointed an ombudsperson to whom staff, business partners and third parties can turn as an external and independent point of contact if they have sufficient grounds to believe that breaches of applicable law or internal regulations have occurred.
Please let the ombudsman know
- which organisation or organisational unit
- and
- when
- where
- which parties were involved
it happened.
The ombudsperson is particularly interested in information regarding possible breaches of applicable law or internal regulations. The Ombudsperson is also interested in knowing which other individuals – including those who may not have been directly involved in the specific incidents – are aware of this, and whether there are any documents (e.g. emails, photos) relating to it.
Before submitting your report, please check carefully that the information you provide is factually correct. In particular, you must not provide any information that you know to be false. Please also let the Ombudsperson know how they can contact you should they have any further questions.
If you are unsure whether the breaches you have observed or suspect are accurate, please use phrases such as “I believe…”, “I think it is possible that…”, “It could be that…”. If you are unsure about how to present the facts, assess the situation and/or proceed, you can discuss the case with the ombudsperson beforehand – anonymously if you wish – and free of charge.
As a solicitor, Dr Johannes Dilling is bound by professional secrecy and may not disclose the identity of a whistleblower known to him to third parties without making himself liable to prosecution. Dr Dilling has taken appropriate technical and organisational measures to protect the reports he receives in such a way that third parties cannot access them. The information that Dr Dilling passes on to the HSRW is also treated as confidential and protected there. The whistleblower may request that Dr Dilling does not disclose their identity to the HSRW.
No, it isn’t.
Firstly, Section 9(2) of the Whistleblower Protection Act provides for exceptions to confidentiality, which, for example, allow the identity of a whistleblower to be disclosed to a law enforcement authority if the latter so requests. Express reference is made to Section 9 of the Whistleblower Protection Act.
Secondly, only those persons who act in good faith – that is, who do not intentionally or through gross negligence provide false information – enjoy protection of confidentiality. Good faith is presumed if, at the time of the report, the whistleblower believes that the information they have provided is true. A whistleblower who intentionally or through gross negligence provides false information must expect that their identity may be disclosed following a request for information from the data subject under Article 15(1) of the GDPR, and that the data subject may assert claims for damages.
Finally, neither Dr Dilling nor the HSRW enjoy protection against seizure; that is to say, in the event of an official investigation, the authorities may seize documents from which the identity of the whistleblower is apparent.
Whistleblowers who fear that their identity may be revealed are therefore advised to submit a report anonymously. Even in the case of an anonymous report, no false information must be provided.
If you are unsure, the same applies here: please use phrases such as ‘I believe…’, ‘I think it is possible that…’, ‘It could be that…’
The Ombudsman is not a dispute resolution body. The relationship of mandate exists solely between the HSRW and the Ombudsman. Nevertheless, the Ombudsman acts impartially and is not bound by instructions from the university. As a lawyer, Dr Johannes Dilling is already bound by law to maintain confidentiality.
The Ombudsperson will acknowledge receipt of the report within 24 hours. The Ombudsperson will check the report for plausibility, prepare it for submission, and forward it confidentially to the HSRW’s Internal Audit, Compliance and Data Protection Unit. Subsequently, the Chancellor and, where appropriate, an ad hoc working group will assess how to deal with the report. If there are sufficiently concrete grounds for suspecting breaches of the law or guidelines, these will be investigated internally in order to clarify and remedy any possible misconduct. This, too, is generally carried out confidentially and discreetly in order to protect the rights of the individuals affected by the report. You will receive a response from the Ombudsperson no later than three months after submitting the report.
You can contact the Ombudsperson by any means available (telephone, email, fax, post or via the whistleblowing system at www.safewhistle.info). The Ombudsperson is also available for face-to-face meetings with whistleblowers, or via video call if requested. If you wish to communicate securely, you can also use the Signal and Threema messaging services to contact the Ombudsperson. It is also possible to send encrypted emails via ProtonMail.
The contact details are as follows:
Dr Johannes Dilling
, Solicitor Landgrafenstraße 49
50931 Cologne
Telephone: +49 (0) 221 933 107 40
Mobile: +40 (0) 163 347 6111
Fax: +49 (0) 221 933 107 42
www.ra-dilling.de
www.safewhistle.info
Threema ID: 3PX6278J
Email: info(at)
External reporting centres
Whistleblowers may also choose to report information about breaches to external reporting bodies.
The external reporting office is, in principle, the
Federal Office of Justice
Adenauerallee 99–103
53113 Bonn
Information on the reporting procedure at the Federal Office of Justice, to which reference is made in accordance with Section 24(4), sentences 1 and 2 of the HinSchG, can be found here:
https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes.html
The online reporting procedure can be found at the following link:
https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html
The competent external reporting body for reports pursuant to Section 21(1) and (2) of the HinSchG is the
Federal Financial Supervisory Authority (BaFin)
Graurheindorfer Straße 108
53117 Bonn
Information on the reporting procedure of the Federal Financial Supervisory Authority, to which reference is made in accordance with Section 24(4), sentences 1 and 2, of the HinSchG, can be found here:
https://www.bafin.de/DE/DieBaFin/Hinweisgeberstelle/hinweisgeberstelle_node.html
https://www.bafin.de/DE/DieBaFin/Hinweisgeberstelle/2_Anonyme_Hinweisabgabe/AnonymeHinweiserteilung_node.html
You can find the online reporting procedure via the following link:
https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=2BaF6&c=-1&language=ger
The competent external reporting body for reports pursuant to Section 22(1) of the HinSchG is the
Federal Cartel Office
Kaiser-Friedrich-Straße 16
53113 Bonn
Breaches may be reported at any time, irrespective of the outcome of any proceedings arising from an internal report.
Information on the Federal Cartel Office’s reporting procedure, to which reference is made in accordance with Section 24(4), sentences 1 and 2 of the HinSchG, can be found here:
https://www.bundeskartellamt.de/DE/Kartellverbot/Anonyme_Hinweise/anonymehinweise_node.html
The online reporting procedure can be found via the following link:
https://www.bkms-system.net/bkwebanon/report/channels?id=bkarta&language=ger
Furthermore, whistleblowers – who may remain anonymous if they so wish – can report possible cases of fraud or other serious irregularities with potentially adverse effects on EU funds to the European Anti-Fraud Office (OLAF):
European Commission
European Anti-Fraud Office (OLAF)
1049 Brussels
Information on the reporting procedure at the European Anti-Fraud Office, to which reference is made in accordance with Section 24(4), sentences 1 and 2 of the Whistleblowing Act (HinSchG), as well as the online reporting procedure, can be found here: https://anti-fraud.ec.europa.eu/index_de