Procedural Rules for the Complaints Procedure under the Supply Chain Due Diligence Act (LkSG)
1. Submission of Complaints and Access to the Whistleblower System
Whistleblowers can report potential violations in the supply chain—anonymously or by name—via vandaglas digital whistleblower system. Reports can be made through voice recording or in text form using the Hintbox system, accessible at the following link: https://vandaglas.lawcode.cloud/hbx/. Employees may also contact their superiors, management, or the human resources department.
2. Parties Involved in the Procedure
Whistleblowers include employees, staff of suppliers and service providers, and other relevant individuals who submit information through the reporting channel mentioned in point 1. Affected departments and internal and/or external experts will be involved as needed.
3. Acknowledgement of Receipt and Feedback
If contact details are provided, whistleblowers will receive an acknowledgement of receipt within the legal timeframe, along with regular updates on the case’s status.
4. Admissibility of the Complaint
The reporting office checks whether the complaint is plausible and if a violation of the LkSG has occurred. To clarify the facts, further questions may be directed to the whistleblower, and internal and external experts may be consulted.
5. Assessment Criteria
Reports of supply chain violations are reviewed based on analyses of suppliers, information from questionnaires on human rights and environmental protection, case-specific dialogues, and, if necessary, audits.
6. Documentation of the Procedure
All reports received through the whistleblower system, as well as follow-up questions and contributions from involved parties, are documented.
7. Independence and Integrity of Procedural Leaders
It is ensured that those leading the procedure act independently, maintain transparency, and guarantee reliability.
8. Location of the Procedure Reporting
Office Address: Austria: vandaglas Eckelt, Resthofstraße 18, 4400 Steyr Netherlands: vandaglas b.v., Meander 451, 6825 MD Arnhem Switzerland: vandaglas AG, Sonnenwiesenstrasse 15, 8280 Kreuzlingen UK: dualseal, 403 Leeds road, Huddersfield HD2 1XU
9. Language of the Procedure
Reports can be submitted in German or English, as well as other languages selectable in the whistleblower system.
10. Duration of the Procedure
The duration of the procedure varies depending on the case; prompt processing is aimed for.
11. Costs of the Procedure
Whistleblowers providing information in good faith and truthfully will not incur any costs.
12. Transparency and Documentation
Incoming reports and all associated correspondence are documented with date and time to ensure seamless traceability.
13. Clarification of Facts
The reporting office designates responsible individuals for clarification, involves them in case handling, and appoints those accountable for the case.
14. Protection of Parties Involved in the Procedure
The confidentiality of whistleblowers is ensured. They are protected from disadvantage or punishment due to a report made in good faith. Legal obligations to pass on information to competent authorities remain unaffected.
15. Implementation and Documentation of Procedure
Results Identified violations are prevented, ceased, or minimised. In our own business area, violations are terminated immediately. Appropriate measures with suppliers may include ending the violation, minimisation with a timeline, or suspension or termination of the business relationship. A report is prepared upon conclusion of the procedure.
16. Review of the Effectiveness of the Complaint Procedure
The effectiveness of the complaint procedure is reviewed at least once a year or as needed.