COMPLAINT MANAGEMENT
Rules of procedure for the complaints procedure in accordance with Whistleblower Protection Act (HinSchG) and Supply Chain Due Diligence Act (LkSG)
I. Introduction
ALWIN KOLB GmbH & Co. KG and its companies (HANS KOLB GmbH & Co. KG, Gebr. KNAUER GmbH & Co. KG, HANS KOLB Papierfabrik GmbH & Co. KG, KOLB Holding GmbH) are committed to respecting human rights and protecting the environment. It is the declared aim of the company management to respect, protect and promote human rights and the environment along the entire value chain. Violations of internationally enshrined human rights and national and international environmental protection regulations will not be tolerated. ALWIN KOLB GmbH & Co. KG and its aforementioned companies take appropriate and effective measures to identify and verify human rights and environmental risks in its own business area and in the entire supply chain and to prevent the realization of risks. The human rights and environmental due diligence obligations include the establishment of an effective complaints procedure through which whistleblowers can report violations, risks and other issues.
These rules of procedure replace the „Complaints Management in accordance with the Whistleblower Protection Act (HinSchG)“ guideline dated August 11, 2023.
These rules of procedure explain the process of submitting and processing incoming complaints. It sets out how the complaints procedure can be accessed, who is responsible for the complaints procedure, what the specific process looks like once a complaint has been received and what measures are taken to protect whistleblowers. The aim of the complaints procedure is to enable whistleblowers to make contact easily and safely so that human rights and environmental risks and violations in the supply chain can be identified at an early stage and any violations that have occurred can be minimized and remedied.
II. Addressees and scope of application of the complaints procedure
The complaints procedure is publicly accessible and is available to all persons – whether in Germany or abroad. The complaints procedure enables individuals to report human rights or environmental risks as well as violations of human rights or environmental obligations caused by the business activities of ALWIN KOLB GmbH & Co. KG and/or its subsidiaries or in the supply chain. The complaints procedure is available for violations of the scope of application of the Whistleblower Protection Act (HinSchG) and/or the Supply Chain Duty of Care Act (LkSG).
III. Procedure
Irrespective of the reporting channel through which a notification is submitted, the procedure is uniform from receipt of the notification.
1. Responsibility for the complaints procedure
The Complaints Management Officer is exclusively responsible for receiving and processing reports, who must act impartially, is obliged to maintain confidentiality and is not subject to any instructions within the framework of the complaints procedure.
2. Submission of a report
In principle, there are various reporting channels available to whistleblowers:
An internet-based reporting portal, which can be accessed in several languages via the following link:
https://www.kolb-wellpappe.com/beschwerdemanagement/ or https://en.kolb-wellpappe.com/complaint/
Postal reports can be sent to the following address:
ALWIN KOLB GmbH & Co. KG
c/o Complaints Office, Dr.-Lauter-Str. 2, D-87700 Memmingen, Germany
Reports can be submitted confidentially or anonymously.
3. Receipt of a tip-off
Upon receipt of a report, the person making the report will receive a confirmation of receipt. The confirmation of receipt is usually sent immediately, although there may be a delay of up to seven days in sending the confirmation of receipt.
4. Processing of the complaint
Once the report has been received, it is reviewed by the complaints management officer as the responsible employee. The complaints management officer maintains contact with the person making the report. The complaints management officer examines the facts of the case and discusses them with the whistleblower if necessary. If a violation of human rights or environmental obligations or violations of the scope of application of the Whistleblower Protection Act (HinSchG) are identified, the Complaint Management Officer will immediately initiate remedial measures. If a human rights or environmental risk arises from a whistleblowing report without a violation having occurred, the complaints management officer initiates preventive measures. Information is taken into account as part of the risk analysis. The results of the fact check are communicated to the whistleblower and, if necessary, further steps are discussed with the whistleblower. Reports are generally processed within three months of receipt.
5. Anonymous submission of a tip-off
Reports can be submitted anonymously. If a tip is submitted anonymously, no data will be collected that would allow conclusions to be drawn about the identity of the person submitting the tip. If the person submitting a report anonymously provides information that allows conclusions to be drawn about their identity, the information will be treated confidentially.
6. Confidential submission of a tip-off
In addition, the confidentiality of personal data and other information that allows conclusions to be drawn about the identity of the person making the report is guaranteed when a report is submitted. Only the complaints management officer can view a report.
7. Documentation of reports
Information is stored for seven years in accordance with § 10 para. 1 sentence 2 LkSG.
Memmingen, June 27, 2024
ALWIN KOLB GmbH & Co. KG
Angela Kolb
CEO