“Both must be guaranteed: Protecting the employees and protecting the FRoSTA company”
Sabine Lemke is Compliance Manager at the well-known manufacturer for frozen meals FRoSTA. The company opted for a whistleblower system long before the Whistleblower Protection Act came into force. LegalTegrity has been in use since 2021. In this interview, Sabine Lemke provides valuable insights into the introduction and communication of the whistleblowing system as well as the processing of reports.
Why did FRoSTA decide to introduce a whistleblower system?
Transparency and trust play a major role at FRoSTA. We believe in fresh products without trickery and label exactly where our ingredients come from. We see feedback as a gift. It was therefore logical for us to introduce a digital whistleblower system – even before the Whistleblower Protection Act came into force.
How did you approach the introduction of LegalTegrity’s whistleblowing system?
We first involved the works council and the data protection officer (in our case this was easy because I am also the data protection officer). The next step was to decide that the reports would be processed by me in Germany and by my colleague in Poland. We adopted a company agreement, and the LegalTegrity templates helped us a lot, as we only had to make minor adjustments. We have included the QR code for the whistleblower system in our Code of Conduct and also published it on our website.
“We adopted a company agreement, an the LegalTegrity templates helped us a lot, as we only had to make minor adjustments.”
Sabine Lemke
In your opinion, what are the biggest advantages of a whistleblowing system like LegalTegrity?
First and foremost, the opportunity to uncover grievances that might otherwise not have been discovered. It was important for us to give employees the certainty that complaints will not go unheard and that we will follow up on every single report. We are also reliant on this, as most things happen “at grassroots level”. Our colleagues in production and the warehouse are close to the product and have insights that I don’t have. Of course, compliance with the Whistleblower Protection Act is now also essential and it was reassuring for me to know that any changes to the law are automatically taken into account in the LegalTegrity system. In our case, there are also other regulations that we comply with using LegalTegrity: we use the tool to comply with the Supply Chain Act, where we have been obliged to report since January 1, 2024. In addition, as a food manufacturer, we are IFS-certified, a food standard. This also requires an anonymous reporting system.
In addition to the technical introduction of the reporting channel, it also includes communication within the company. How did you approach the topic of “speak-up culture” at FRoSTA?
We have developed a whole range of communication measures. Starting with a poster that we have physically hung up in all our branches and run digitally on our screens. This poster is available in four languages and can be easily scanned using a QR code. Here, too, the templates from LegalTegrity were helpful for the creation. Many of our colleagues work in production. The poster is also placed on screens there. The “tone from the top” was very important to us. Our CEO Felix Ahlers recorded a video about the whistleblowing system, which we also published via all available channels, such as our intranet. The whistleblower system is an integral part of the induction plan for new employees. New applicants are also made aware of this.
Do you receive a lot of reports?
When we introduced the system, we noticed that many things were reported in order to test: Does it work? Is it really anonymous? Now there are fewer reports, most of which are relevant issues. We have been able to uncover a few things and have been able to adapt the processes accordingly. Things are relatively quiet at the moment, so we are planning new communication measures again. It is important to regularly remind employees of the system.
Do you mainly receive legally relevant information? Or do you also receive other types of “expressions of dissatisfaction”?
Displeasure reports are also submitted, but this also changes over time. We point out what compliance-relevant cases are in trainings and on the intranet. As a result, the reports are becoming more and more important. Nevertheless, even reports that don’t seem so relevant at first glance can provide valuable information about the mood in the company. Like a kind of barometer.
How do you manage the follow-up of relevant information? Do you proceed alone?
It is often necessary, for example, to involve supervisors and conduct interviews. We proceed alone as far as necessary, but ultimately certain people almost always have to be involved. We take care not to mention any names and only describe the facts. In this way, we ensure that confidentiality is maintained. Both must always be guaranteed: Protecting employees and protecting the FRoSTA company.
Did something go wrong in the process? From today’s perspective, what would you possibly do differently?
I would involve even more employees in the process of introducing the reporting channel. In the beginning, people often talked about it as a “gripe channel” on the “office grapevine”. I think this can be avoided by involving managers even more at an early stage, for example.
Do you have any tips on how the false connotation of “denunciation” can be clarified with employees and trust in the whistleblower system can be established?
Show your face. In my case, that means going into production, traveling to other locations and talking to people. This builds trust. Employees then also realize through experience that we take reports seriously and treat them confidentially. Another important factor is that the management must be behind it. That is the most important thing for all compliance issues.
