Remmers Gruppe SE and all domestic companies affiliated with it within the meaning of Art. 15 AktG (hereinafter jointly referred to as Remmers) provide a complaints procedure to enable anyone to draw attention to human rights and environmental risks as well as to the violation of human rights-related or environmental obligations within the meaning of Section 2 LkSG, which may have arisen as a result of Remmers' or a supplier's business activities.
With these rules of procedure, Remmers defines clear framework conditions that ensure that all incoming complaints are handled in accordance with the legal requirements of Section 8 LkSG.
The aim of a complaints procedure is to gain knowledge of human rights or environmental risks or violations that have already occurred as early as possible so that remedial and preventive measures can be taken quickly and effectively.
1. Scope of these Rules of Procedure within the meaning of Section 8 LkSG and admissibility
These Rules of Procedure apply to all complaints, including anonymous complaints, submitted via the Remmers complaints system by one or more persons ("complainants") about human rights or environmental risks, or about the violation of human rights or environmental obligations within the meaning of § 2 LkSG, which have arisen as a result of the business activities of Remmers or a (direct or indirect) supplier ("complaint").
Complaints that are based on deliberately false factual allegations or are submitted for the purpose of discrediting another person or Remmers are not to be classified as complaints within the meaning of these Rules of Procedure.
2. Principles of procedure
Remmers, in the person of the external human rights officer entrusted by Remmers with the management of the complaints system, carefully investigates the reported facts, conducts the complaints procedure swiftly and transparently and discusses the facts with the complainants, provided that they have communicated their availability when submitting the complaint or the digital complaints portal on this platform has been selected as the complaints channel. The complainants are informed about the status of the procedure, its conclusion and the measures derived and decided upon. The complaints procedures carried out are documented and it is ensured that the complainants are not disadvantaged or penalised.
3. Complaint channels
The following complaint channels are available to complainants:
Remmers digital complaints portal
in writing, by telephone or through a personal meeting with the external human rights officer
in writing by e-mail
Information on how to reach the various complaint channels (telephone number, e-mail address, postal address) can be found in the description of the individual complaint channels.
4. Description of the complaints procedure
The complaints procedure is as follows:
Once a complaint has been received, the complainant will receive confirmation of receipt of the complaint within seven days of receipt, provided that the complainant's contact details were also communicated when the complaint was submitted, or the digital complaints portal in this platform was selected as the complaints channel.
The external human rights officer in charge of the complaints system examines the reported facts for plausibility and urgency and contacts the complainants to obtain further information if necessary.
The external human rights officer investigates the reported facts comprehensively, taking into account the rights of all parties involved in the proceedings, and discusses the content of the complaint with those responsible at Remmers. The external human rights officer is subject to the lawyer's duty of confidentiality and will not disclose the identity of the complainant to third parties without the prior consent of the complainant.
If a human rights or environmental risk has been identified that has been caused by the business activities of Remmers or a supplier, Remmers will take immediate remedial and/or preventive action to end the violation or minimise its impact. This may also include the development of a prevention concept together with the complainant and the supplier.
At the end of the procedure, the complainants are informed of the results of the investigations and the measures taken.
The findings from the complaints procedure are evaluated and used as the basis for improvements to the risk analysis and the complaints procedure at Remmers. The complaints procedure is documented and its findings are included in the annual report to be published. The complaints system is reviewed on an ad hoc basis, but at least once a year.
5. Protection of the complainant
Remmers ensures that complainants employed by it are protected from penalties or other disadvantages as a result of submitting a complaint within the framework of the legal requirements.
Remmers will also take action on behalf of complainants employed by suppliers to ensure that they are not penalised for making a complaint.
In both cases, the principle of protecting the identity of the complainant applies, according to which the external human rights officer responsible for conducting the complaints procedure may become aware of the identity of the complainant, but will not disclose it to third parties within the framework of the legal requirements and without the prior consent of the complainant. Personal data is always collected, processed, transmitted and stored in the complaints procedure in compliance with Section 10 (1) LkSG.
The Management Board of Remmers Group SE
September 2023