Rules of procedure for the complaints procedure
in accordance with § 8 section 2 of the Act on Corporate Due Dilligence Obli-gations in Supply Chains (LkSG)

What is the complaints procedure for?

The subject of a complaint can be reports and information on human rights and environmental risks as well as on violations of human rights or environmental obligations by Glatt and by third parties along our supply chain within the meaning of the LkSG (“information”). This includes the following risks and violations of human rights or environmental obligations:

    • Child labor, all forms of slavery and forced labor
    • Violations of applicable occupational health and safety regulations
    • Disregard for freedom of association, freedom of association and the right to collective bargaining
    • Unequal treatment of employees
    • Payment of inappropriate wages
    • Failure to comply with the prohibition on causing harmful soil change, water pollution, air pollution, harmful noise emissions or excessive water consumption
    • Failure to comply with the ban on unlawful eviction
    • Failure to comply with the prohibition on hiring or using private and public security forces if this violates freedom of association, life and limb or the prohibition of inhumane treatment
    • Failure to comply with the ban on the manufacture of mercury-added products or the use of mercury and compounds in the production process, as well as the treatment of mercury waste (Minamata Convention of October 10, 2013)
    • Failure to comply with the ban on the production and use of chemicals in accordance with Article 3 (1) letter a and Annex A of the Stockholm Convention of May 23, 2001
    • Failure to comply with the ban on the non-environmentally sound handling, storage and disposal of waste, the export and import of hazardous waste in accordance with the Basel Convention of March 22, 1989

Who can use the reporting office?

Anyone is entitled to report information on potential human rights or environmental risks and violations.

Which reporting channels are available?

Information on human rights and environmental risks as well as violations of human rights or environmental obligations can be submitted by name or anonymously to a competent and reliable service provider commissioned by us, who you can contact as follows:

Address:

UIMCert GmbH
Meldestelle der Glatt GmbH
Otto-Hausmann-Ring 113
42115 Wuppertal

E-Mail: meldestelle.glatt@uimcert.de

Phone: +49 202 – 946 772 66 111

How does the complaints procedure work?

After receipt of a report via the above-mentioned reporting channels, the whistleblower will receive confirmation of receipt. If the facts described involve human rights or environmental risks or violations of human rights or environmental obligations by Glatt or third parties along the supply chain within the meaning of the LkSG, the information will be forwarded to us. We investigate the information and check whether there are human rights or environmental risks or whether human rights or environmental obligations have been violated. In connection with their processing, compliance with applicable laws, confidentiality and fairness in dealing with the whistleblower are ensured. All information is treated as strictly confidential and is only reviewed by persons who have committed to confidentiality or are obliged to maintain confidentiality.

The facts of the case are discussed (if possible and necessary) with the whistleblower with the aim of gaining a better understanding of the facts of the case and the measures to be taken.

The legal assessment of the facts and the determination of suitable measures will be carried out by us. If desired by the whistleblower, we will work towards an amicable settlement of the dispute.

As the whistleblower, you can contact the complaints office at any time to find out about the status of the matter. The rights of those affected must be respected when providing feedback. The whistleblower will be informed of the outcome at the latest after the investigation has been completed, to the extent permitted by law.

The duration of the complaints procedure depends on the complexity of the respective report, but should be carried out swiftly and without major interruptions.

Safeguarding anonymity

The information is submitted to an external reporting office. This external reporting office forwards the information to us anonymously. Glatt has therefore opted for an external reporting office in order to protect the whistleblower particularly well. It is also possible to submit a report anonymously. However, a non-anonymous report enables a direct dialog with the whistleblower and improves the chance of finding a quick solution. However, if you wish to remain anonymous, provide as many details as possible and, if available, documents. Only if there are sufficiently concrete investigation approaches and possibilities for providing evidence can a report ultimately have an effect.

What do I have to fear if I make a report?

If you, as a whistleblower, provide information via the above-mentioned reporting channels, you will be protected. However, the complaints procedure may not be used to make false statements or to deliberately report false information. You therefore do not have to expect any disadvantages, provided that you have made your report on the basis of concrete evidence and you are convinced to the best of your knowledge and belief that the information provided is correct.

Is data protection complied with?

Compliance with data protection regulations and statutory retention obligations is ensured (see also our information sheet on data protection).

Is the effectiveness of the complaints procedure reviewed?

The effectiveness of the complaints procedure is reviewed by us once a year and on an ad hoc basis if we have to reckon with a significantly changed or significantly expanded risk situation in our own business area or at our direct supplier.