Reporting on breaches of Union law (Whistleblower protection)

Dethlefsen & Balk GmbH has a great interest in detecting and remedying legal violations within the company. Not only employees of a company, but also other persons who have a professional relationship with the company are often the first to become aware of possible violations. By providing information, they can help to ensure that these can be investigated and prevented. Whistleblowers therefore play an important role in the investigation and prevention of violations and in promoting legally compliant and ethical behavior at Dethlefsen & Balk GmbH.

In order to fulfill our legal obligations and to enable you to confidentially report possible violations of applicable law, we have set up an internal reporting office and entrusted the law firm Scheja & Partner Rechtsanwälte mbB with the operation of this reporting office. You can submit reports of violations via the reporting office, also completely anonymously. Your reports will be processed by selected lawyers while maintaining the confidentiality of your identity.

When you submit a report, you leave the Dethlefsen & Balk GmbH website and are forwarded to the reporting office, which is operated outside the company infrastructure.

Further information on the internal reporting office and the processing of your personal data can be found on the website of the reporting channel.

Reporting human rights violations and environmental offences

Rules for the complaints procedure pursuant to Section 8 of the Supply Chain Act (LkSG)

What is it about?

Dethlefsen & Balk GmbH supports equitable supply chains. In order to avoid human rights violations and to comply with environmental standards in its own business area and within the supply chain, all due diligence obligations are implemented in accordance with the Supply Chain Act. A core element of these obligations is an appropriate complaints procedure and the establishment of a reporting centre to identify signs of risks to people and the environment and avert possible consequences.

Which complaints can be reported?

The complaints procedure is open to reports of imminent or actual violations of international human rights or reports concerning non-compliance with environmental standards that arise from the context of Dethlefsen & Balk GmbH's business activities, in its own business area or within the supply chain. These may therefore be concrete indications or suspected cases.

Examples:

Human rights violations

• Child labour
• Forced labour and slavery
• Discrimination and unequal treatment
• Disregard for freedom of association
• Denial of an appropriate wage
• Health-endangering working conditions
• Unlawful forced evictions or the unlawful seizure of land
• Unlawful use of private or public security Forces

Violations of environmental law

• Use of mercury (in accordance with the Minamata Convention)
• Use of persistent organic pollutants (according to the Stockholm Convention)
• Improper storage, handling, import and export of hazardous waste (in accordance with the Basel Convention)
• Contamination of drinking water

Who can submit complaints?

The reporting system is public and is available to all internal and external persons in Germany and abroad.

How can a complaint be submitted?

Complaints can be submitted online at any time, in text form or as a voice message via the following link:

Anonymity and confidentiality

Complaints can generally be submitted anonymously. If a complaint is submitted anonymously, no data is collected that would allow conclusions to be drawn about the identity of the person submitting the complaint. If the person submitting a complaint provides information that allows conclusions to be drawn about their identity, the information will be treated confidentially. Only the person in charge and the person responsible for allocating the report can view a complaint.

Protection of persons who submit a complaint

We strive to ensure that people who inform us of (potential) hazards are not penalised or punished as a result of their report. Retaliation based on complaints will not be tolerated. If the person making the report is employed by our company, we will ensure that no reprisals are taken.

For example, if the reporting person is employed by a supplier, we will work with the supplier to ensure that the person enjoys a comparable level of protection. To ensure that the reporting person is not subject to any discrimination, punishment or similar retaliation, we endeavour to maintain ongoing contact with the reporting person, even after the procedure has been completed.

Responsibility for the complaints procedure

Only specially trained employees are responsible for receiving and processing complaints. They act impartially, are obliged to maintain confidentiality and are not under any instructions as part of the complaints procedure.

Contact person for complaints management: Jessica Waltereit

How does the process work?

1. A written confirmation of receipt of the complaint is sent within 2 weeks
2. Examination of the facts.
3. Clarification of the facts.
4. Development of a proposed solution with the reporting person.
5. The agreed preventive or rectifying measures are implemented and followed up.
6. Review, finalisation and documentation of the procedure.
7. Evaluation of the results with the reporting person.

The duration of the proceedings depends heavily on the facts of the case and can range from a few days and weeks to several months. In principle, we endeavour to bring the proceedings to a satisfactory solution as efficiently as possible. We also keep the reporting person regularly informed about the progress of the proceedings.