Supply chain protection law
Rules of procedure for the complaints procedure under the Supply Chain Due Diligence Act (LkSG)
Systemo GmbH & Co. KG has set up a complaints procedure by appointing an external lawyer as an ombudsman (lawyer of trust), thereby sending a clear signal in favour of human rights protection, environmental protection and a responsible corporate culture.
Area of application
The complaints procedure is available to anyone, in particular all employees, business partners and other third parties, in order to draw attention to human rights and environmental risks as well as to the violation of human rights-related or environmental obligations under the LkSG, which may have arisen as a result of the business activities of Systemo GmbH & Co. KG or a supplier.
Complaints based on deliberately inaccurate factual claims or complaints submitted for the purpose of discrediting another person or Systemo GmbH & Co. KG are not to be classified as complaints within the meaning of these Rules of Procedure.
The receipt of the complaint is documented by the ombudsman and confirmed to the complainant within seven days. As part of this confirmation of receipt, the complainant is also informed of the next steps, the timeline for the procedure and the rights to which they are entitled with regard to protection against discrimination or penalisation as a result of the procedure.
The ombudsman checks whether the complaint received falls within the scope of the complaints procedure and forwards the anonymised complaint to the Human Rights Officer of Systemo GmbH & Co. KG. In the event of a rejection, the complainant will be briefly informed with reasons.
The Ombudsman discusses the facts of the case with the complainant in a needs-orientated manner. In dialogue with the Human Rights Officer and the relevant specialist department of Systemo GmbH & Co. KG, a proposal for prevention and/or remedial action is then drawn up if a human rights or environmental risk is identified which is caused by the business activities of Systemo GmbH & Co. KG or a supplier.
Appropriate preventive and/or remedial measures are implemented and followed up in order to end the violation or minimise its impact. The result achieved can be jointly evaluated at the request of the complainant. The effectiveness of the procedure is reviewed annually and on an ad hoc basis. If necessary, adjustments are made to the procedure or remedial measures taken.
The findings from the complaints procedure are evaluated and used as a basis for the further development of the risk analysis and the complaints procedure. The complaints procedure is documented and its findings are included in the annual report to be published.
Identity protection and protection against reprisals
The confidentiality of the complainant’s identity is maintained at all times. The identity of the complainant is only known to the ombudsman if the complainant has previously disclosed his or her identity. The ombudsman is contractually obliged to maintain confidentiality vis-à-vis Systemo GmbH & Co. KG.
Furthermore, Systemo GmbH & Co. KG does not accept any reprisals against a complainant.
Contacting the ombudsman
The ombudsman can be contacted by telephone, e-mail or post. A personal meeting is also possible on request:
Lawyer Robert Buchmann
Phone +49 (0) 89 244 40 93-22
Fax +49 (0) 89 244 40 93-65
Mobile +49 (0) 152 54 64 85 68