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Complaint and Reporting Procedure Procedure

in accordance with §8 Supply Chain Act

Date: 22.12.2023

1. Scope

This document outlines the procedure for reporting complaints and concerns under §8 of the Supply Chain Act (LkSF). It applies to the entire Sennebogen and all affiliated entities, irrespective of location and business area.

Company-Wide Applicability: This procedure is applicable to all employees, managers, and other members of the concerned entities of the Sennebogen, including temporary staff, interns, and freelancers. Inclusion of Third Parties: Suppliers, business partners, and other third parties can also utilize this procedure to report potential violations of human rights or environmental regulations.

Context: Reports can pertain to activities within the affected entities of the Sennebogen or in its supply chain. This includes violations committed directly by one of the affected entities of the Sennebogen, an employee, a business partner, or an indirect or direct supplier.

2. Subject of Complaint

This procedure covers reports concerning potential violations of the requirements of §8 of the Supply Chain Act (LkSG):

  • Violations of Human Rights: Including, but not limited to, discrimination, forced labor, child labor, infringement of labor rights, harassment, or other unethical treatments of employees and other involved parties.
  • Violations of Environmental Laws: Including, but not limited to, air, soil, and water pollution, improper waste disposal, non-compliance with environmental regulations, or other actions contravening existing environmental protection laws.

Any person who becomes aware of the mentioned risks or violations can file a report, regardless of whether they are personally affected by such a risk or violation and irrespective of whether it occurred in Germany or abroad.

The report should, if possible, include specific details to enable efficient review and processing. However, it is not necessary for the reporting person to know the exact legal basis of the potential violation.

3. Reporting and Responsibilities

Reports related to the Supply Chain Act (LkSG) can be submitted via this online form. Complaints through this online form are generally possible at any time. The person responsible for reports of Sennebogen is accountable for the initial assessment and processing of the report and, if necessary, forwards it to the internal investigation department for a comprehensive examination. In more complex cases or the need for independent review, external legal professionals or other consultants may also be involved. All reports are treated strictly confidentially, and the affected entities of Sennebogen take all necessary measures to protect the identity of the reporting person unless the person expressly agrees to disclosure.

4. Processing and Notification

For Sennebogen, the focus is on a transparent and thorough processing of each report. Once a report is received, it is carefully examined by the person responsible for reports or the relevant department. This may involve forwarding to internal or external experts for a comprehensive analysis. This process is designed for the quick and effective processing of reports without neglecting the quality of the examination. Subsequently, an analysis is conducted to determine which investigations are to be carried out to clarify the facts underlying the report. The reporting person is informed about the receipt of their report and the progress of the processing, provided they have voluntarily provided personal data. Notification can be, for example, via email. Communication with the reporting person is an essential part of the procedure to establish transparency and trust.

5. Confidentiality and Data Protection

The Sennebogen takes the protection of privacy very seriously and commits to treating all information submitted through this reporting system confidentially. The identity of the reporting person, as well as all information related to the report, is handled strictly confidentially and shared only with those who absolutely need to be involved in the process. There is also the option to submit reports anonymously. The software for the internal online form is configured to protect the identity of the reporting person unless they expressly choose the option to disclose their identity. In accordance with current data protection regulations and policies, including the General Data Protection Regulation (GDPR), all personal data collected in the context of this reporting system is used only for the purpose of processing the report and is retained or deleted in accordance with legal requirements after the investigation is concluded. Access to the data is strictly limited to the person responsible for reports and those involved in the investigation process. All parties involved are obliged to comply with confidentiality and data protection regulations to ensure the privacy of reporting persons is protected.

6. Protection and Legal Consequences

Trust in the process and the protection of those who submit a report are of the highest priority for the Sennebogen. Individuals who submit a report in good faith can be assured that they are protected from any form of disadvantage. This includes but is not limited to protection from harassment, discrimination, or unfair treatment in the workplace. The protection of the reporting person starts with the receipt of the report and extends throughout the entire investigation process. Those involved in the investigation are obligated to absolute confidentiality and the protection of the identity of the reporting person unless they have expressly agreed to disclosure. We are aware that safeguarding the rights of all parties involved is crucial. Therefore, fairness and righteousness are always considered during the investigation of reports. If the investigation reveals a violation of laws or company policies, appropriate measures will be taken to address the matter. These measures may include disciplinary actions, legal steps, or other measures tailored to the specific situation. The Sennebogen promotes a corporate culture where compliance with laws and ethical guidelines is taken seriously, and employees are encouraged to report concerns or potential violations without fear of retaliation. This approach strengthens the trust of all parties involved and contributes to maintaining the integrity and righteousness of the entire supply chain.

7. Effectiveness & Review

We commit to regular monitoring and evaluation of the complaint procedure in accordance with §8 of the Supply Chain Act (LkSG) to ensure its ongoing effectiveness. The review includes effectiveness assessments, analyzing the implementation of the procedure, and identifying trends and potential areas for improvement. Internal or external audits may be conducted as needed. Changes and improvements are implemented based on the results of these reviews to ensure that the procedure complies with current laws and business requirements. We will review this document and the described procedure at least annually or in the event of significant changes to relevant legislation or business requirements. The results of the reviews will be communicated transparently and serve the continuous improvement and adaptation of the procedure.

The entity responsible for implementing and complying with this statement is:

Sennebogen

For all company internal criminal or administrative offenses: