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Our global compliance organization aims to ensure compliance with internal and external regulations and with our company requirements.

The compliance management system is an important part of our “three lines of defense” model and is part of the second line of defense involving risk management and control. For more information, please see the risk management report.

Taking account of the reporting of internal and external stakeholders is an important part of the compliance management system. Our whistleblower system ensures that potential violations of the rules are identified, clarified and stopped in good time. Any reports are treated fairly, immediately and adequately and with the utmost confidentiality.

Whistleblower system and compliance

WACKER has a global whistleblower system (based on the EQS reporting platform) that is available to whistleblowers both internally and externally and is fully accessible across the globe. Reports can be submitted in person or anonymously via the whistleblower system or other reporting channels (help desk, group mailbox, email, telephone or in person) or via an external hotline. They can also be forwarded to local compliance officers, managers or employee representatives. In the USA, WACKER also offers an additional option for reports in the form of the Navex software platform. The whistleblower process is continuously reviewed to identify any need for updates or optimization and is updated accordingly as necessary.

Communication and transparency

In 2025, communication regarding the global whistleblower process and the underlying reporting channels was expanded further and the topic was addressed, by way of example, in local compliance training sessions to raise greater awareness. Social audits in employee interviews are one of the tools used to inquire as to employees’ knowledge of the whistleblower system.

Across the Group, further communication measures were taken, including appealing poster campaigns to raise awareness of the whistleblower process, and new forms of personal, accessible and confidential dialogue on compliance culture and corporate values were introduced (e.g. in the form of the “DialogRaum” concept).

Reports of potential compliance risks or violations are investigated immediately, independently and impartially. The underlying process is described on the intranet and on the company’s website. The decision to launch a compliance investigation is based on circumstances in individual cases and on the findings of the initial evaluation.

Reporting channels and protective measures

Reports of potential violation of the rules can be submitted by employees, business partners, customers and other third parties via various channels and in several languages. These reports are received by WACKER Group Compliance or the relevant contacts, which conduct thorough and appropriate investigations confidentially and in good time. Protecting whistleblowers and the individuals concerned is one of the basic principle’s of our whistleblower system. We respect the right to confidentiality and we uphold the presumption of innocence and fairness of investigations.

Investigation process

1. Submission of a report: Reports can be sent to Group Compliance at any time and in any language as part of an accessible system. Group Compliance reviews every report that it receives thoroughly and systematically in line with company rules. Whistleblowers receive confirmation of receipt – provided that a mailbox has been activated or contact details are available – and can also receive ongoing information as well as final feedback after an investigation has been completed.

2. Investigation of the matter: if suspicion of a violation of the rules is justified, an investigation is launched. The underlying company rules, investigation principles and the very highest standards of confidentiality are taken into account as part of this process. Investigations involve and take into account the necessary experts, specialist knowledge and company-specific conditions. Investigation results are evaluated from a legal perspective and, depending on the findings, appropriate action is taken.

3. Further course of action: the outcome of the investigation will determine whether process-related changes, expansion of monitoring mechanisms or disciplinary measures are taken. Relevant reports are communicated to the necessary units within the company, taking confidentiality and privacy requirements into account. Where possible, whistleblowers are informed and notified of the status of the investigation and any findings, in accordance with the relevant company rules.

Protection from retaliation

WACKER has established extensive measures to afford protection from retaliation in line with the German Whistleblower Protection Act (HinSchG). This includes training and confidential meetings (sometimes at a later date) with whistleblowers, individuals under suspicion, and other parties that provided information. We make it our utmost priority to protect the right to privacy, data-protection regulations and confidentiality. Once an investigation has been completed, follow-up action is initiated by the departments responsible. In selected cases, Group Compliance contacts whistleblowers again to verify the effectiveness of the protective measures and to rule out any form of retaliation in collaboration with other business units involved (employee representatives, HR, human rights officer).

Compliance regulation

Our identification, reporting and investigation mechanisms are set out in our internal guidelines, particularly in the Group’s Compliance regulation. The Group’s Compliance regulation describes the underlying conditions and procedures in the global process for reporting (potential) compliance risks and violations. This regulation is reviewed on a regular basis to ensure it is up to date and if it is not, it is adapted as required.

In the fiscal year under review, two new supplements to the Compliance regulation were introduced and published on the topics of “Anti-money laundering” and "Ruling out breaches of competition and antitrust law”.

Our global compliance organization is independent and not bound by any instructions. Our investigation officers (the Group Compliance Officer and Corporate Auditing employees) or any investigation committees that have been set up (e.g. the local compliance committee or human rights committee) are independent of the management chain involved. Necessary investigations are initiated independently, neutrally, without delay and confidentially if the evidence available can be easily comprehended and an investigation is justified.

Compliance and antitrust training

Compliance and antitrust training courses are mandatory training courses that must be completed by all employees every two years groupwide. During the reporting period, training sessions and workshops were also held worldwide to further implement WACKER’s Group-wide Code of Conduct and raise awareness of other compliance-specific topics and preventive measures. Our qualification rate worldwide in the reporting period was over 90 percent (2024: over 90 percent).

Functions that are at high risk of bribery and corruption include Procurement & Logistics and Sales & Distribution Management.

In the year under review, we established and rolled out compliance safeguards and a fundamental strategy for managing our worldwide distributors within Sales & Distribution Management. This strategy includes a comprehensive conceptual review of incidents, the definition of standard processes and assessment methods, and specific compliance training measures. Web-based compliance training is provided for every sales partner that is to work for WACKER. This ensures comprehensive compliance management for WACKER’s global sales partners and distributors.

Communication and compliance policies

WACKER communicates its policies on its intranet and company website as well as in dedicated workshops and training courses. During the reporting period, the “tone from the top” message was refined with regard to WACKER’s global sales partners and was communicated at target group-specific training sessions.

All employees have access to the global company rules via the company’s document management system, dedicated intranet pages and other communication measures, and they are provided with corresponding information and training in this regard. The global Code of Conduct and other publications relating to compliance can also be found on the corporate website.