Compliance is now more complex than ever.
The legal challenge continues to grow across the globe.
This is why we must keep adjusting our processes and systems to meet current legal requirements.
To highlight the importance of Compliance, we have based our Company policy on the following principle:

 

“We comply with applicable laws and internal directives”

 

Compliance has therefore become an important part of our corporate culture.
Lidl promotes a Compliance management system that allows its employees, business partners and customers to meet all standard and binding processes.
Lidl has also adopted a Code of Conduct inspired by the values ​​of ethics, professional integrity and independence.
To ensure Compliance it is important to identify conduct that is not in line with the Company's Compliance principles as quickly as possible.
Lidl therefore needs to receive reports of breaches and, for this, we trust in the support of our employees, business partners and customers.
If you are aware of a possible Compliance breach, you can report it through any of the channels listed at paragraph 2 below.

 

1. What is a Compliance breach?

The following types of offence by Lidl employees or third parties can be reported:

 

a) corruption, in any form, offences against the public administration, corporate crimes, environmental offences or breaches, whether confirmed or presumed, of Lidl’s Code of Conduct;
b) violations of antitrust or competition law;
c) violations of regulations on product safety, including food products;
d) violations of personal data protection rules.

 

2. How do I make a report?

You can report a Compliance breach in any of the following ways.
Lidl reserves the right not to take into consideration verbal and/or telephone communications not formalized in the manner indicated below

 

  2.1 Via Business Keeper Monitoring System (BKMS)

All reports relating to violations, whether confirmed or presumed, referred to in paragraph 1 above, can be made in writing via the BKMS system.

BKMS is an online portal provided by Business Keeper AG that can be accessed from any internet-connected device that uses electronic methods (via a secure https protocol) and encryption to protect the identity of the whistleblower and his/her report (and any accompanying documents). The Compliance Officer of Lidl (“Compliance Officer”) will receive all reports sent and is responsible for their examination.

For more information on the BKMS online reporting system, please see the brochure downloadable from:

 

Brochure

 

Use the following link to make a report via BKMS:

Report BKMS

 

 

  2.2 To the Compliance Officer

 

All reports concerning violations, whether confirmed or presumed, as per paragraph 1 above may also be made in writing by contacting the Compliance Officer, Mrs. Barbara Quattrini, directly at the following address:

 

E-mail:                        compliance@lidl.com.mt

 

The Compliance Officer is responsible for the examination and process of the reports.

◘◘◘

 

If the report concerns a potential violation of personal data protection law, the Compliance Officer may contact the Data Protection Officer of Lidl.

 

 

3. Which guarantees and protection does Lidl provide?

Pursuant to the Maltese Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta), Lidl's reporting procedures ensure that:

 

a) the identity of the whistleblower and of the content of his/her report will remain totally confidential. The name of the whistleblower cannot be disclosed without his/her agreement unless required by law;
b) the identity of the reported person will remain totally confidential. During investigation of that person's possible liability, he/she must be protected against reports made by colleagues or third parties simply in order to damage his/her reputation;
c) direct and indirect acts of retaliation and discrimination against whistleblowers as a result of their reports are void, but anyone making a false report will be subject to criminal or civil action.

 

Anonymous reports will not be considered unless properly documented.

 

The safeguards mentioned above are subject to the good faith of the whistleblower; therefore, such safeguards are excluded in the event of fraud (defamation) or gross negligence. Anyone who makes a substantiated report and is reasonably certain that the unlawful conduct reported did occur or was committed by the reported person will be considered to have acted in good faith.

 

Lidl carefully and confidentially checks all reports of Compliance breaches.

 

Reports that do not concern Compliance matters will not be processed. For all other matters, please contact our Customer Service:

 

Customer Service

 

4. How will the personal data of the whistleblower and the reported person be processed?

Both persons' personal data will be processed in accordance with the Maltese Data Protection Act (Chapter 586 of the Laws of Malta) and any Subsidiary Legislation issued under the same as may be amended from time to time, Regulation (EU) no. 679/2016 and our privacy policy, which can be downloaded from the following link:

Privacy policy for the whistleblower and for the reported person