German Supply Chain Due Diligence Act „LkSG“

Violations of human rights-related obligations (§ 2 (2) LkSG) or environmental obligations (§ 2 (3) LkSG), such as:

• Violation of the prohibition of child labour (Nos. 1 and 2)
• Violation of the prohibition of forced labour and all forms of slavery (Nos. 3 and 4)
• Disregard for occupational health and safety and work-related health hazards (No. 5)
• Disregard for freedom of association, the right to organise and the right to collective bargaining (No. 6)
• Violation of the prohibition of unequal treatment in employment (No. 7)
• Withholding an adequate wage (No. 8)
• Destruction of the natural basis of life through environmental pollution (No. 9)
• Unlawful violation of land rights (No. 10)
• Violation of the prohibition on commissioning or using private or public security forces whose inadequate instruction or supervision may lead to harm (No. 11)
• Violation of the prohibition of an act or culpable omission that is directly capable of impairing a protected legal position (= another human right) in a particularly serious manner and whose unlawfulness is evident upon reasonable assessment of all relevant circumstances (No. 12)
• Violation of a prohibition arising from the Minamata Convention (Nos. 1–3)
• Violation of the prohibition on the production and/or use of substances within the scope of the Stockholm Convention (POPs), as well as the environmentally unsound handling of waste containing POPs (Nos. 4 and 5)
• Violation of the prohibition on the import and export of hazardous waste within the meaning of the Basel Convention (Nos. 6–8)

To ensure your anonymity, you must take the following steps: 

• If possible, do not submit the report from a computer provided by your employer.
• Do not use a computer connected to the company network or intranet. 
• Access the reporting system by entering the URL directly into your  browser rather than clicking on a link.
• Do not include any personal information in the report.

When submitting your report, you have the option to create a secure mailbox and remain available for future enquiries.

We recommend remaining contactable in this way, as we may not be able to conclude the case without further information from you.

When you create a mailbox, you will be assigned a case ID and will need to choose a password. You must use this case ID and password to access the mailbox and check whether you have received any questions.

Regardless of whether you remain anonymous or provide your name, we ask you to create a mailbox. This makes it easier and more secure for us to communicate with you.

If you wish, all communication with us will remain anonymous.

Complaints Procedure

pursuant to §§ 8 and 9 of the Act on Corporate Due Diligence Obligations in Supply Chains (also known as the Supply Chain Due Diligence Act – “LkSG”)

Under the German Supply Chain Due Diligence Act (LkSG), companies are required to observe human rights-related and environmental due diligence obligations within their supply chains in an appropriate manner, with the aim of preventing or minimising human rights-related or environmental risks or ending violations of human rights-related or environmental obligations.

The complaints procedure enables both those directly affected and those who are aware of potential or actual violations to notify our company of possible risks or violations.

The Rules of Procedure for the complaints procedure under the LkSG govern the procedure within our company in cases involving suspected human rights-related or environmental risks or violations of these protected legal interests.

A complaint under the LkSG may concern reports of human rights-related and environmental risks or violations arising from the economic activities of our company within its own business operations or those of a supplier. These include violations of human rights-related (§ 2 (2) LkSG) or environmental (§ 2 (3) LkSG) obligations, such as:

•      Violation of the prohibition of child labour (Nos. 1 and 2)

•      Violation of the prohibition of forced labour and all forms of slavery (Nos. 3 and 4)

•      Disregard for occupational health and safety and work-related health hazards (No. 5)

•      Disregard for freedom of association, the right to organise and the right to collective bargaining (No. 6)

•      Violation of the prohibition of unequal treatment in employment (No. 7)

•      Violation of the prohibition on withholding an adequate wage (No. 8)

•      Destruction of the natural basis of life through environmental pollution (No. 9)

•      Unlawful violation of land rights (No. 10)

•      Violation of the prohibition on commissioning or using private or public security forces whose inadequate instruction or supervision may lead to harm (No. 11)

•      Violation of the prohibition of an […] act or culpable omission that is directly capable of impairing a protected legal position (= another human right) in a particularly serious manner and whose unlawfulness is evident upon reasonable assessment of all relevant circumstances (No. 12)

•      Violation of a prohibition arising from the Minamata Convention (Nos. 1–3)

•      Violation of the prohibition on the production and/or use of substances within the scope of the Stockholm Convention (POPs), as well as the environmentally unsound handling of waste containing POPs (Nos. 4 and 5)

•      Violation of the prohibition on the import and export of hazardous waste within the meaning of the Basel Convention (Nos. 6–8)

Complaints may be submitted by affected persons and third parties (§ 8 (1), sentence 1 LkSG), as well as by potential participants in the supply chain (§ 8 (4), sentence 2 LkSG). The complaints procedure is available both internally and externally.  

Our company takes precautions to ensure the confidentiality of the identities of reporting persons and the protection of their personal data. For this purpose, a secure mailbox can be created and used throughout the procedure, enabling anonymous communication.  

Complaints under the LkSG concerning human rights-related and environmental risks or violations can be submitted using the dedicated tool provided for this purpose. The tool enables prompt communication via a secure mailbox.  

After a complaint has been submitted by the reporting person, the reporting office examines whether it falls within the scope of the complaints procedure. If it does, the complaint will be accepted.  

If it does not fall within the scope of the complaints procedure, it will be referred to the responsible department. The reporting person will receive confirmation of receipt within seven days and, where applicable, an explanation of the referral. Once the report has been received, it will be assessed and classified as reported misconduct (triage) or as a risk to the reporting person and relevant interested parties (adverse consequences), so that appropriate measures can be established in the next step.  

The reporting office investigates the report.

Where applicable, follow-up information and responses to further questions from the reporting person may be required. The reporting person will receive feedback on the subject matter of the complaint within three months of submitting the report. This feedback may take the form of a recommendation or a decision. Depending on the reported circumstances, appropriate preventive and remedial measures will be applied to address the subject matter of the complaint and bring the procedure to a conclusion that is satisfactory to both parties.