The General Terms and Conditions of Purchase and the Lieferkettensorgfaltspflichtengesetz (LkSG) (German Act on Corporate Due Diligence Obligations in Supply Chains) from the point of view of Hastamat and the Piepenbrock Group

The complaint procedure can be utilized by anyone who wishes to report indications of actual or suspected legal violations, breaches of the code of conduct, or violations of guidelines regarding a company within the Piepenbrock Group. This applies to employees of these companies, members of corporate or operational management, as well as business partners or third parties.

The complaint procedure allows for reporting of actual or potential misconduct, violations of regulations or laws related to a human rights violation or an environmentally related risk defined in the Supply Chain Act. Reports can also include human rights and environmental risks as well as violations of human rights or environmental obligations arising from the business activities of a company within the Piepenbrock Group in its own business area or of a direct or indirect supplier. The selection in the "Type of Violation" tab in the complaint form helps you correctly categorize a report. Further information can be found in our Statement of Human Rights Strategy or in the official text of the Supply Chain Due Diligence Act.

The procedure is not available for general complaints, product and warranty inquiries, or individual legal advice. Only those indications should be provided where the informant has reasonable grounds to believe that the information reported or disclosed by them is true.

The identity of the informant is protected by law and contractual agreements with the contracting companies. The identity of the informant is only disclosed if such disclosure is necessary for subsequent measures and the informant expressly consents to it. The identity of an informant who knowingly or recklessly reports false information is not protected.

Reports can also be submitted anonymously through the complaint procedure. For effective follow-up, it may be necessary to ask the informant for further details. Therefore, the Complaints Office, the Human Rights Officer, will encourage the informant to provide their contact information for any inquiries. The identity of the informant will be treated confidentially.

The company bears the costs of the complaint procedure. However, anyone who knowingly or recklessly reports false information and thereby causes damage is obligated to compensate for the damage.

The Complaints Office, the Human Rights Officer, will document the report and confirm receipt of the report to the informant within seven days. They will assess the validity of the report and, if possible and necessary, ask the informant for further details.
The Complaints Office, the Human Rights Officer, will provide a summary of the report, as well as all necessary information for follow-up actions, while ensuring confidentiality, to the relevant person or department within the company responsible for initiating corrective actions. The Human Rights Officer oversees further processing and the implementation of corrective actions.

The Complaints Office, the Human Rights Officer, will provide feedback to the informant within three months of the receipt confirmation, including planned or already implemented corrective actions and the reasons for these actions. If providing feedback would adversely affect the rights of individuals mentioned in the report or impede or prevent internal investigations, feedback may exceptionally not be provided or may be provided without specifying corrective actions or reasons.

Employers may not disadvantage or threaten employees in response to the submission of a report or assistance in submitting a report, provided that there was at least reasonable grounds to believe that the reported or disclosed information is true. A so-called burden of proof reversal applies in this regard. For example, if an employee is dismissed after submitting a report, the employer must prove that the dismissal did not occur because of the submission of the report.