TDK Electronics · TDK Europe


Public complaint and reporting procedure

Compliance with applicable laws and internal policies is a core responsibility of corporate governance and a top priority for TDK. 

The purpose of the whistleblower channel is to prevent violations of law and internal rules by identifying risks as early as possible, investigating possible violations and taking appropriate action. In this context, information that is provided by employees or by third parties is of particular value. 

For more detailed information about the public complaint and notification process, please see the following sections:

Who can file a complaint?

The public complaint and reporting procedure is available to anyone, including:

  • all employees of the TDK Electronics Group worldwide, including all business groups as well as subsidiaries and sales companies;
  • all employees of TDK companies outside the TDK Electronics Group based in the EMEA region, (e.g., TDK-Lambda and InvenSense companies);
  • third parties outside of TDK, (including, but not limited to organizations, suppliers, agents and other individuals affected by TDK’s corporate activities or business).

What can I report?

Any violation of applicable laws or internal company rules, as well as corresponding suspicious cases, may be reported. The suspicion may be directed at an individual employee or it may be related to a TDK business. Whistleblowers should not conduct their own investigation to determine whether a suspicious case is a violation of law or company rules. TDK expects that whistleblowers will not intentionally and/or knowingly make false reports, but will act to the best of their knowledge and in good faith and make reports that they believe to be true.

In particular, the following may be reported: 

  • Human rights violations
  • Violations of environmental, health and safety regulations
  • Anti-competitive behavior
  • Corruption and bribery 
  • Information security 
  • Misuse of company property 
  • Export control violations 
  • Theft, fraud, embezzlement and money laundering 
  • Conflicts of interest 
  • Other misconduct (e.g., discrimination, harassment) 

Employees can always report violations directly to their manager. In addition, there are several different reporting channels that employees and third parties can use to submit reports. 

These reporting channels are described in more detail in the following sections. 

Online whistleblowing portal

TDK Electronics has established an online whistleblowing portal. This allows electronic reporting in multiple languages 7 days a week, 24 hours a day. The online whistleblowing portal is managed by an independent operator. The data is stored on secure servers in Germany. Only a few selected TDK Electronics Compliance Officers may access, evaluate and process complaints or reports. 

The whistleblower can access the report at any time by assigning a password and individual key code. This process allows for further communication between the compliance officer and the whistleblower, anonymously if desired.

Online whistleblowing portal

What other report submission options do I have?


Reports may also be submitted by email to the following address: 

Postal message

Reports can also be sent by postal mail to the following address:

TDK Electronics AG 
Chief Compliance Officer 
Legal Department & Compliance 
Rosenheimer Street 141e 
81671 Munich 

Will the identity of the whistleblower be kept confidential?

All reports will of course be treated confidentially. The confidentiality of the report and the identity of the whistleblower are of the utmost importance to TDK Electronics. 

Reports are handled according to a strict ‘need-to-know’ principle. This ensures that the smallest possible group of people is involved in the processing of reports. TDK Electronics will respect and maintain the anonymity of the person who submits the report, if requested, throughout the entire process, except in the following cases: 

  • the person providing the information consents to the disclosure of his or her identity and/or report; 
  • the disclosure is necessary for TDK Electronics’ compliance with a legal obligation or vis-à-vis authorities; 
  • the disclosure is made by TDK Electronics as part of its cooperation with government authorities. 

Reports can be made without revealing names or identities. The online whistleblowing portal contains specific technical measures to ensure the anonymity of the whistleblower. However, anonymity can only be guaranteed if the whistleblower does not provide any information that would allow the identity of the whistleblower to be inferred. 

How are whistleblowers protected?

No one who makes a report in good faith will be penalized, discriminated, or otherwise retaliated. It does not matter whether the information provided ultimately proves to be completely true or not. 

If a whistleblower believes that he or she has been discriminated against, retaliated against, or otherwise adversely affected as a result of making a report, the whistleblower may contact TDK’s compliance officers by using the channels mentioned above. TDK’s compliance officers will investigate each report.

Who is responsible for processing incoming reports?

Reports are generally handled by the TDK Electronics Legal & Compliance Department in Munich, Germany, which acts as the central reporting office for all complaints and reports, regardless of the channel through which they are reported. 

Reports are handled by a dedicated TDK compliance officer. The employees responsible for handling reports are impartial, independent, not bound by instructions and sworn to confidentiality. Depending on the nature of the report, selected employees from specialized departments may be involved on a ‘need-to-know’ basis to obtain relevant information and clarify the facts.

Are all of the reported cases being addressed?

Every report received is taken seriously. The first step is to determine whether the report contains sufficient information for further clarification of the facts. If further information is needed, the compliance officer will contact the person who provided the information, if possible.

What happens to the message after it has been sent?

Acknowledgement of receipt

Each report received will be documented internally. Within seven days of receiving the report, the whistleblower will receive an acknowledgement of receipt.

Using the online whistleblowing portal

If the whistleblower submitted a report through the online whistleblower portal, he or she will receive a unique key code. This is regardless of whether the report was submitted anonymously or not. This key code must be noted and retained by the whistleblower and is the whistleblower’s personal key to his/her report.

The whistleblower can use his or her individual key code to submit additional information and communicate with the TDK compliance officer responsible for the report at any time via the website of the online whistleblowing portal. The individual key code must be provided each time the whistleblower logs in to access his or her report on the online whistleblowing portal.

Plausibility check and categorization of the message

The content of the incoming report is first checked for plausibility and categorized according to the severity of the issue. The report is prioritized according to its urgency. 

Message verification

The compliance officer assigned to review the report will verify the facts underlying the report. If the review of the facts is not possible due to a lack of sufficient information, the compliance officer will contact the whistleblower to obtain additional information, if possible. To the extent required by law, the compliance officer will discuss the report with the whistleblower. This will only be done if the whistleblower wishes to do so and provides an opportunity for contact. Therefore, when using the online whistleblowing portal, the whistleblower will be asked to log in to the online whistleblowing portal from time to time to respond to inquiries from the compliance officer. Again, this can be done anonymously at any time. 

If the report is incomplete or implausible, for example, because it does not contain sufficient factual information and it is not possible to contact the person providing the information, the case may be closed. 

Investigation of the facts

An investigation involves reviewing and analyzing all relevant documents and data and, where possible, interviewing witnesses and affected parties. The goal is to conduct a quick and objective investigation in order to provide a neutral and appropriate assessment. 

Duration of the investigation process

The processing time depends on the subject matter of the report and may take from a few days to several months, depending on the complexity of the report. However, the company will make every effort to complete the processing of reports in a timely manner. 

Conclusion of the investigation

If the investigation confirms a violation of applicable laws or internal regulations, appropriate follow-up actions, e.g., preventive or corrective measures, are taken. In some cases, this may include appropriate disciplinary action. Decisions on follow-up-actions will be based on the principle of proportionality (i.e., whether the action is appropriate, necessary and proportionate in the particular case). If the investigation does not confirm a violation of applicable law or company rules, the matter will be closed.

To the extent possible and permitted by law, the person providing the information will be notified in an appropriate manner of the conclusion of the investigation.