The German Act on Corporate Due Diligence to Prevent Human Rights Violations in Supply Chains (Lieferkettensorgfaltspflichtengesetz - LkSG), which came into force on January 1, 2023, aims to better protect human rights and the environment in the global economy.
In order to fulfil these objectives, we have set up an effective appeal procedure in accordance with Section 8 LkSG. The aim is to prevent violations of the LkSG as far as possible or to identify them at an early stage in order to avoid possible negative consequences for those affected.
Business partners, customers and other third parties can use the appeal procedure to report violations of human rights and environmental obligations and the associated risks, anonymously if desired.
Human rights obligations include the prohibition on child labor, protection against slavery and the ban on disregarding occupational health and safety. The environmental aspects include, on the one hand, substances that pose a risk to people and the environment and, on the other hand, actions or circumstances that may lead to violations of human rights.
In the following, we have described the reporting channels, responsibilities and the exact procedure for reporting by means of procedural rules.
Procedure
In the following, we would like to explain the exact process of a notification.
1. Receipt of Notice
Upon receipt of the notice, the reporting person will receive a confirmation of receipt from the reporting office in due time. This also applies in the case of an anonymous report by mail, provided that a reporting channel intended for the submission of anonymous reports, e.g. via a third party (lawyer or authorised person) is used or another anonymous contact option is available.
2. Examination, clarification of facts and remedial measures
The report is then carefully checked for plausibility. If further information is required, the Reporting Office will, if possible, contact the reporting person in order to obtain further information.
If there are concrete indications of a violation, an internal investigation and possibly further appropriate follow-up or remedial measures (e.g. improvement of internal processes) may be initiated.
The information is processed as part of a fair and confidential process, in particular with regard to the identity of the person providing the information, and in compliance with data protection law. Furthermore, the principle of proportionality is observed.
Discrimination or punishment of the whistleblower based on a complaint about an actual or suspected violation will not be tolerated. To this end, we have set up an independent reporting office and the option of submitting an report anonymously.
Where possible, contact is maintained with the whistleblowers in accordance with the relevant legal requirements and the facts of the case are discussed if necessary. In addition, the whistleblowers are informed of the progress of the proceedings in a timely manner.
Information provided will only be passed on to those persons who need to be involved in order to process the report, insofar as this is absolutely necessary to determine the facts of the case.
All information received is documented, stored and deleted in accordance with the statutory provisions.
3. Effectiveness Control
Our appeal procedure is regularly reviewed with regard to its effectiveness and improved where necessary.