Compliance | Geis Group
  • Compliance

Complaint Procedure of the Geis Group

For the Geis Group, compliance with legal regulations, internal rules and the Code of Conduct is a high priority. The success of our company is based on employee orientation, integrity, sustainable management, and compliance. In addition, fair competition, avoidance of conflicts of interest and respect for human rights are the benchmarks for our actions.

The complaint procedure is intended to fulfil two important functions in relation to dealing with human rights risks and environmental risks as well as in dealing with violations in the company’s own business area and in the supply chain: The complaint procedure serves as an early warning system to ensure that problems are identified and, in the best case, resolved before there’s harm to the people or the environment. Effective complaint procedures also provide access to appropriate remedies when needed.

How does the Geis Group manage the complaints/observations

The Geis Group has a complaints procedure through which both internal and external persons can contact the company. The complaints procedure can be used for all human rights risks and environmental risks, i.e., breaches of duty. The procedure should also be used if improper business practices have been observed in the company.

The complaints procedure is the responsibility of the Sustainability Department. The process of the procedure according to the Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz, LkSG) is controlled and coordinated by the Human Rights Officer and/or his/her deputy. The function of the ombudsperson according to the Whistleblower Protection Act (Hinweisgeberschutzgesetz, HinschG) is also performed by the Human Rights Officer.

1. Receipt of the Complaint or observation

Receipt is confirmed to the person providing the information and documented on the Geis Group intranet.

If there are any queries or if further information is required, the person providing the information will be contacted.

2. Examination of the Complaint or observation

At the beginning of the procedure, it is checked whether the complaint/observation falls within the scope of the complaint procedure.

Feedback to the whistleblower will be provided within seven days of receipt of the complaint/observation at the latest. The acknowledgement of receipt will inform the whistleblower of the next steps, the timing of the procedure and their rights in relation to protection from disadvantage or punishment as a result of the procedure or the use of other formal complaints procedures.

In the event of a refusal, the whistleblower will receive a statement of reasons.

3. Clarification of the Facts

The contact person discusses the facts with the whistleblower with the aim of gaining a better understanding of the situation. The expectations of the whistleblower regarding possible preventive or remedial measures are also discussed.

If necessary, the human rights officer and/or his/her representative will contact the persons responsible internally and clarify the situation. This process is documented for follow-up purposes.

Feedback is provided to the whistleblower no later than three months after receipt of the complaint/ observation.

4. Developing a Solution with the Whistleblower

Building on step 3, a proposal for a remedy is worked out in an exchange with the whistleblower. If necessary, arrangements for redress are also made.

5. Remedial Measures

Remedial actions are implemented and tracked in the IMS action list.

6. Review and Conclusion

The achieved result is evaluated together with the whistleblower.

7. Effectiveness Review

The effectiveness of the procedure is reviewed annually and on a case-by-case basis together with the management. Adjustments to the procedure or remedial action taken will be made as necessary.

Documentation

The documentation in accordance with the Act on Corporate Due Diligence Obligations in Supply Chains and the Whistleblower Protection Act is listed in the Geis Group’s processing directory in accordance with the GDPR and continuously documented on the Geis Group intranet.

The documentation in accordance with the complaint procedure pursuant to the Act on Corporate Due Diligence Obligations in Supply Chains must be kept for at least seven years from its creation.

The documentation in accordance with the complaint procedure pursuant to the Whistleblower Protection Act must be kept for at least two years from its creation.

Complaint Channels

Supply Chain Observations/Complaints:


E-mail: lieferkette@geis-group.de
Hotline: +49 (0) 9771 603-95957 (can be reached Monday - Friday 9 am to 5 pm)
Outside the times when the telephone hotline is staffed, a message can be left on the voicemail.
Via post: Confidential: Human Rights Officer
Hans Geis GmbH & Co KG, Rudolf-Diesel-Ring 24, 97616 Bad Neustadt, Germany
In person: If a personal appointment is desired, please contact us via the above channels to make an appointment.

Observations/Complaints about Violations in Your Own Company


E-mail: hinweisgeber@geis-group.de
Hotline: +49 (0) 9771 603-95957 (can be reached Monday - Friday 9 am to 5 pm)
Outside the times when the telephone hotline is staffed, a message can be left on the voicemail.
Via post: Confidential: Ombudsperson Whistleblower Protection Act
Hans Geis GmbH & Co KG, Rudolf-Diesel-Ring 24, 97616 Bad Neustadt, Germany
In person: If a personal appointment is desired, please contact us via the above channels to make an appointment.
Confidentiality

In order to guarantee the confidentiality of the identity of the whistleblower as well as the protection of their personal data, all data is stored in a protected area on the Geis Group file server, to which only employees of the Sustainability Department have access. It is also possible to submit information anonymously.

The necessary confidentiality of identity and data protection are guaranteed in accordance with the GDPR.

The Human Rights Officer and/or his/her deputy act impartially and independently and are not bound by instructions and are obliged to maintain confidentiality.

Protection against disadvantage or punishment due to filing a complaint

Whistleblowers will be protected from discrimination or punishment for using the complaints procedure. The Geis Group is committed to not tolerating retaliation for filing complaints or observations.

Both its own employees and suppliers will be followed by appropriate consequences commensurate with the severity of the reprisal.

It is advisable to remain in contact with the whistleblower even after the procedure has been completed in order to ensure that he or she is not subsequently endangered by retaliatory measures.

External Reporting Procedure

If no agreement can be reached in the complaint/ reporting processes under the Whistleblower Protection Act, the whistleblower can turn to the following offices:

  • External Reporting Office of the Federation at the Bundesamt für Justiz (German Federal Office of Justice) (Whistleblower Protection Act §19)
  • External Reporting Offices of the German Länder (Whistleblower Protection Act §20)
  • Bundesanstalt für Finanzdienstleistungsaufsicht (German Federal Financial Supervisory Authority) as an external reporting office (Whistleblower Protection Act §21)
  • Bundeskartellamt (German Federal Cartel Office) as an external reporting office (Whistleblower Protection Act §22)
  • Other external reporting offices (Whistleblower Protection Act §23)
Copyright 2023 Geis Gruppe. All Rights Reserved.