Rules of Procedure for the Complaints Procedure under the LkSG
according to § 8 (para. 2) of the German Supply Chain Due Diligence Act (in German Lieferkettensorgfaltspflichtengesetz (LkSG))
Our complaints procedure is intended to enable people to report when they identify actual or potential problems in the area of human or environmental rights. These can be problems in our supply chains, but also in our own area of business. These rules of procedure describe which issues can be reported, how they can be submitted and what happens after a report has been made.
Scope
In principle, all issues in the area of human rights and environmental rights violations can be reported via this reporting system. Specific examples are:
Human rights violations:
- Child labour
- Forced labour and slavery
- Discrimination and unequal treatment
- Disregard for freedom of association
- Withholding of a decent wage
- Working conditions that are hazardous to health
- Unlawful eviction or deprivation of land
- Unlawful use of private or public security forces
- Pollution of water, soil and air that may contribute to human rights violations
Environmental rights violations:
- Use of mercury (under the Minamata Convention).
- Use of persistent organic pollutants (under Stockholm Convention)
- Failure to store, handle, import or export hazardous waste in an environmentally sound manner (under Basel Convention)
Submitting notifications and complaints
We recommend submitting information via our digital reporting system:
https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=12len14&c=-1&language=ger
Reports can be submitted in your preferred language. The submission of reports is possible 24/7. If desired, whistleblowers can remain completely anonymous. Even if whistleblowers disclose their identity, confidentiality and the protection of personal data are guaranteed in any case.
Through the system, reporting persons - even if they remain anonymous - can stay in contact with an external lawyer even after submitting a report. The use of the system is, of course, free of charge for the person providing the information.
Procedure
The processing of all incoming reports follows a structured process, which is described below.
1. Receipt of the report
Upon receipt of the report, whistleblowers receive a confirmation of receipt, usually within seven days of receipt of the report. Of course, this assumes that the whistleblower has set up an (anonymous) mailbox. Unfortunately, people who have not set up a mailbox cannot be contacted.
2. Review of the report
The content of the report is subsequently checked. In this phase, questions may arise which are clarified in dialogue with the whistleblower. Depending on the content, the further procedure is determined. If the complaint is rejected, the whistleblower receives a statement of reasons.
3. Clarification of the facts
If the procedure continues, the issue is discussed and examined with the whistleblower. Optionally, a procedure for consensual dispute resolution may be suggested.
4. Remediation
Remediation measures may be necessary to resolve reported problems. If remediation measures have been agreed, they will be implemented and followed up.
5. Review and closure
The whistleblower will be informed about the result of the investigation (if a postbox was set up).
The duration of the procedure strongly depends on the respective facts and can range from a few days and weeks to several months. In principle, we strive to lead the proceedings to a satisfactory solution as efficiently as possible. In addition, we always try to keep the whistleblower informed about the measures taken and the further course of the case. For this purpose, we recommend that whistleblowers who use the digital reporting system log in regularly and check their own case for new messages.
Settlement of disputes by mutual agreement
In the case of some complaints, it may be advisable to involve a neutral and mediating third party. In this way, we would like to contribute to finding a satisfactory solution that can be supported by all parties. If it becomes apparent during the procedure that an agreement-based settlement of the dispute could be useful, we will endeavor to involve such a neutral party.
Responsibility for the complaints procedure
Centrally responsible for our complaints procedure and primary contact person(s) for questions or comments:
Lenzing Group Compliance Officer:
Florian Wirth
E-Mail: f.wirth@lenzing.com
We also recommend that whistleblowers use the option of communicating via our digital reporting system to address questions or comments directly to the responsible processor.
Protection from disadvantage or punishment
We make an effort to ensure that whistleblowers do not suffer discrimination or punishment as a result of their report. We will not tolerate retaliation for making a complaint or providing information. If the whistleblower is employed by our company, this includes protection against termination, demotion, suspension, threats, harassment, or other discrimination with respect to the terms or conditions of employment of a person.
For example, if the reporting person is employed by a supplier, we will strive together with the supplier to ensure that the person has a comparable level of protection. In order to ensure that the whistleblower is not subject to discrimination, punishment or similar retaliation, we will seek to maintain contact with the whistleblower beyond the conclusion of the case.
Lenzing, 01.01.2024