1. Purpose and scope of application
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 meet these objectives, we have set up an effective complaints procedure in accordance with Section 8 LkSG. The aim is to avoid 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.
In particular, business partners, customers and other third parties can use the complaints procedure to report violations of human rights and environmental obligations and the associated risks, anonymously if they wish.
The human rights obligations here include the prohibition of child labor, protection against slavery and the prohibition of disregarding occupational health and safety. 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, the responsibilities and the exact procedure for reporting by means of procedural rules.
2. Reporting channels
In order to guarantee the greatest possible protection for whistleblowers and those affected, we have set up an independent trust center, the atarax group of companies.
The following communication channels are available to ensure complete confidentiality:
Whistleblower telephone hotline at: 0049 / 160 / 96210839 (Monday – Friday from 08.30 – 17.00, except on public holidays)
By e-mail to: compliance@atarax.de
Via a whistleblower portal with contact form: https://www.atarax.de/de/startseite/leistungen/hinweisgeberportal The link will redirect you to the whistleblower portal of the atarax group of companies. Of course, even this forwarding is not traced.
Written notification by post to: atarax Unternehmensgruppe, Luitpold-Maier-Str. 7, D-91074 Herzogenaurach
At the request of the whistleblower, it is also possible to make a report via these channels within a reasonable period of time as part of a confidential personal meeting.
Digital whistleblower system at https://zeller-gmelin.interne-meldestelle.de
3. Procedure
In the following, we would like to explain the exact process of a notification.
a) Receipt of the notice
Upon receipt of the notification, the notifying person will receive a confirmation of receipt from the registration office within the deadline. This also applies in the case of an anonymous report by post, provided that a reporting channel intended for the submission of anonymous reports, e.g. via a third party (lawyer or authorized person) is used or another anonymous contact option is left.
b) Examination, clarification of facts and remedial measures
The report is then carefully checked for plausibility. If further information is required, MROS will, if possible, contact the reporting person 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 within the framework 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 regulations. The principle of proportionality is also 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 anonymous report.
Where possible, contact is maintained with the whistleblowers in accordance with the relevant legal requirements and, if necessary, the facts of the case are discussed. 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 must be involved in processing 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.
c) Effectiveness control
Our complaints procedure is regularly reviewed with regard to its effectiveness and improved where necessary.
Commercial Management
Alexandra Scaglione