The Welle Group assumes responsibility for respecting and strengthening internationally recognized human rights within its own business areas and through appropriate management of its supply chains. Welle Holding AG + Co KG and its companies implement all requirements of the German Supply Chain Due Diligence Act (LkSG) for the fulfillment of human rights and environmental due diligence obligations and comply with their implementation.
An essential core element of these due diligence obligations is the establishment of an effective complaints procedure through which information on human rights and environmental risks or violations can be submitted.
These rules of procedure provide information on the main features of the complaints procedure, access to the procedure and its availability as well as responsibilities. Furthermore, it also provides information on what happens with incoming information and complaints, i.e. how the complaints procedure is carried out. It is important to Welle Holding AG + Co KG and its companies to present this information in an understandable and comprehensible manner and to create the greatest possible transparency about the process.
What is the purpose of the complaints procedure?
The complaints procedure is intended to give any person or group of persons the opportunity to submit relevant complaints or information to Welle Holding AG + Co. KG and its subsidiaries and thus draw attention to human rights and environmental risks (early warning system).
However, persons or groups of persons are also given the opportunity to report suspected violations so that damage can be averted or minimized immediately (access to appropriate remedy).
Who is the complaints procedure aimed at? Who can submit complaints or reports?
Any person can submit complaints and reports, regardless of whether they are made in Switzerland or abroad.
What types of information or complaints can be submitted?
The complaints procedure enables people to report human rights and environmental risks as well as violations of human rights or environmental obligations that have arisen as a result of the business activities of Welle Holding AG + Co KG and its companies in its own business area or in the supply chain.
How can I submit complaints or reports?
The following complaint channels are available to complainants:
digital complaints portal of Welle Holding AG + Co. KG
in writing, by telephone or in a personal meeting with the external representative
in writing by e-mail
Information on the availability of the various complaint channels (telephone number, e-mail address, postal address) can be found in the description of the individual complaint channels. All complaints and reports are processed immediately.
Who processes the complaints and reports?
Complaints or reports are processed by selected and specially trained external representatives of Welle Holding AG + Co KG.
All persons responsible for processing have the following characteristics. They are:
impartial
independent
not bound by instructions
sworn to secrecy
appropriately trained
equipped with sufficient time resources
How does the complaints procedure work?
Once a complaint or tip-off has been received, the person making the tip-off receives confirmation. This confirmation of receipt is sent within approximately one week, provided that the complainant's contact details were provided when the complaint was submitted or the digital complaints portal on this platform was selected as the complaints channel.
Throughout the entire procedure, the officer will be in contact with the person making the complaint, if this is desired and there is a possibility of contact.
The complaints or reports are initially examined centrally in order to determine whether the reported facts represent a human rights or environmental risk or a violation of human rights or environmental obligations. It is also checked which company or supplier is affected by the report. The external representative is subject to a duty of confidentiality and will not disclose the identity of the complainant to third parties without the prior consent of the complainant.
The next step is to clarify the facts of the case, which generally takes place within three months. If, in the course of clarifying the facts, it is established that a violation of human rights and/or environmental obligations is imminent or is already taking place, remedial measures are initiated immediately.
The persons involved in the complaints procedure follow up on whether and to what extent the remedial measures are implemented.
In addition, a proposal for further action is drawn up based on the findings of the investigation.
How are whistleblowers protected against discrimination and reprisals on the basis of a complaint or a whistleblowing alert?
The protection of whistleblowers against discrimination or punishment on the basis of complaints or information provided is an important part of our complaints procedure.
The following measures are in place to protect whistleblowers:
All complaints and tips are only processed by a small group of selected and specially trained persons.
All information, such as personal data and other information that allows conclusions to be drawn about the identity of the whistleblower, is treated confidentially. This also applies after the procedure has been completed.
Personal data is always collected, processed, transmitted and stored in the complaints procedure in compliance with Section 10 (1) LkSG.
In accordance with legal requirements, internal company documentation is stored for seven years and then destroyed.
Welle Holding AG + Co KG and its companies protect whistleblowers from discrimination or punishment on the basis of a complaint.
The management of Welle Holding AG + Co. KG
December 2023