Transparency, discretion, and fairness are at the heart of how Deutsche Börse Group handles whistleblowing. We talked to our Group Money Laundering Reporting Officer (MLRO), Michael Köhn, and our Group Chief Privacy Officer (CPO), Heiko Drebes, about how we ensure the highest standards of protection for whistleblowers and all parties involved.
Heiko Drebes & Michael Köhn
Heiko Drebes & Michael Köhn
Why is it important to offer a safe channel for whistleblowers in a company like Deutsche Börse Group?
Michael: Whistleblowers play a critical role in upholding integrity and compliance. We want to empower individuals to speak up when they see something concerning – whether it’s related to financial misconduct, data privacy, or any other issue – without fear of negative consequences.
Heiko: We recognize that speaking up takes courage, and that’s why it’s essential to provide a framework that guarantees anonymity where possible and ensures that the person making the report is protected from any form of retaliation.
Let’s talk about confidentiality. How is a whistleblower’s report treated once submitted?
Michael: Every report is handled with the highest level of discretion. We assess each report individually and ensure that only the relevant personnel are involved. Where an investigation is necessary, we limit access strictly to those who need to know, avoiding unnecessary involvement from multiple departments or individuals.
Heiko: Confidentiality is also a legal and ethical obligation. The identity of the whistleblower – as well as the accused and any witnesses – is protected throughout the process. All data is handled in compliance with applicable privacy laws, and no step is taken lightly.
What can employees expect after they submit a report? Will there always be a large-scale investigation?
Michael: Not necessarily. Each report is reviewed thoroughly but proportionally. Some cases may be resolved quickly if no misconduct is found or if the issue is minor and can be corrected informally. Only where necessary, a more formal investigation will be initiated. The presumption of innocence always applies to individuals mentioned in the report.
Heiko: Fairness and objectivity guide our entire process. We aim to protect everyone involved and ensure that nobody is unfairly stigmatized or judged before the facts are established. With respect to privacy complaints, we as the data protection officers are obliged to follow up on the even smallest hint, but limited to what is appropriate in each individual case.
How do we ensure whistleblowers are protected – from both retaliation and a legal standpoint?
Michael: We take whistleblower protection extremely seriously. Our Whistleblower Policy makes it clear: there is absolutely zero tolerance for any form of retaliation against individuals who report concerns in good faith. This means that whistleblowers will not face disciplinary action, demotion, dismissal, or any other disadvantage as a result of coming forward. Beyond internal enforcement, our policy is fully aligned with applicable EU and national whistleblower protection laws, which mandate strong safeguards. The policy outlines not only the rights of whistleblowers but also the confidentiality measures and fair process we follow to ensure their safety and dignity throughout the entire reporting and investigation process.
Heiko: Protecting whistleblowers is fundamental to maintaining trust and integrity within our organization. We encourage employees to speak up when something doesn’t seem right, and we want them to feel completely safe in doing so. If someone experiences or witnesses any form of retaliation, we urge them to report it immediately – it will be treated with the same seriousness as the original issue raised. In addition to adhering to legal requirements, we aim to go above and beyond by fostering a speak-up culture where everyone understands that raising concerns is a responsible and valued act. This protection also extends to those mentioned in the report, ensuring fair treatment for all parties involved.
What happens if colleagues have concerns but aren't sure whether they’re serious enough to report?
Heiko: Not every concern will come with clear evidence or certainty, and that’s okay. If something doesn’t feel right – whether it's a potential compliance issue, misconduct, or anything else that seems off – we encourage colleagues to report it anyway. It's not the employee’s role to investigate or prove anything; it’s our responsibility to assess the concern fairly and confidentially. Even if it turns out to be a misunderstanding, raising it is still the right thing to do.
Michael: We’d rather be made aware of something early than risk missing a potential issue because someone felt unsure. Reporting in good faith – meaning with honest intentions – is always supported, even if the concern doesn't ultimately result in an investigation. You won’t face negative consequences for speaking up, and you don’t need to have all the facts. We’re here to listen, assess, and guide the process responsibly.
