In these Rules of procedure, the Privatärztliche Laborgemeinschaft informs about the course of the complaint procedure set up in accordance with Sections 8 and 9 of the German Supply Chain Due Diligence Act (LkSG). The complaint procedure represents an essential component in the fulfillment of human rights and environmental due diligence obligations in accordance with legal provisions.
We as the Privatärztliche Laborgemeinschaft acknowledge expressly the respect for human rights and are committed to respecting human rights in our own business activities and in our supply chains and to providing those affected by human rights violations access to remedial action. We align our business activities with the internationally recognized guiding principles for business and human rights of the United Nations and thus implement the requirements of the LkSG. An effective complaint procedure helps us to detect potential violations of human rights and environmental due diligence obligations at an early stage and to initiate appropriate countermeasures. As part of this, we promise all those who provide information that all incoming reports and complaints will be treated confidentially and professionally.
The Privatärztliche Laborgemeinschaft counts the companies affiliated with it as its own business area within the meaning of the LkSG. This complaint procedure also applies to these companies.
Who can make reports or complaints?
The complaint procedure is aimed at all potentially affected persons. This includes the employees of the Privatärztliche Laborgemeinschaft and its associated companies, the direct and indirect suppliers and their employees as well as other third parties.
For what types of reports or complaints can you use our complaints procedure?
The complaint procedure can be used to provide serious reports about risks relating to human rights, environmental standards or their violations through economic activities in the own business area of the Privatärztliche Laborgemeinschaft and of the business partners along the supply chain.
The risks according to Section 2 LkSG include in particular: prohibition on child labour, prohibition on forced labor and all forms of slavery, prohibition of disregarding the occupational safety and work-related health risks, prohibition of disregarding the freedom of association - freedom of association and the right to collective bargaining, prohibition on unequal treatment in employment, prohibition of withholding an adequate wage, prohibition of destruction of the natural basis of life through environmental pollution, prohibition of unlawful violation of land rights, prohibition of the hiring or use of private/public security forces, the can lead to impairments due to a lack of instruction or control, prohibited production, use and/or disposal of mercury (Minamata Convention), prohibited production and/or use of substances within the scope of the Stockholm Convention (POP) as well as non-environmentally sound handling of waste containing POPs, prohibited import/export of hazardous waste in the meaning of the Basel Convention.
Which complaint channels do we use to receive your report/complaint?
In order to receive your comments and complaints, the Privatärztliche Laborgemeinschaft provides an official digital reporting channel, which is maintained by CBH Services UG with the support of LegalTegrity GmbH: www.wisplinghoff.de/lieferkette. Here you have the opportunity to submit also anonymous reports. The digital reporting channel is available in German and English.
If you would like to contact us directly to make your reports/complaints, please send us an e-mail to: legal@wisplinghoff.de.
Who is responsible for processing reports/complaints?
The internal legal department and the law firm CBH Rechtsanwälte are responsible for processing the information. These complaints officers guarantee impartial action, act independently and without instructions within the scope of their function and are obliged to maintain confidentiality.
Procedure – What happens after the report or complaint has been submitted?
Acknowledgement of receipt
Incoming reports or complaints in the digital reporting channel are received as follows: Reports from our own employees regarding human rights and labour rights are received by CBH Rechtsanwälte. Reports from our own employees regarding environmental standards as well as all reports from all other potential whistleblowers are received by legal staff in the legal department. In all cases, receipt of the complaint will be acknowledged within one week. For this purpose, submitted reports and complaints as well as their status can be viewed via an access code with a PIN in the reporting channel. It is therefore very important for the person providing the information to keep the access code and PIN in a safe place. Whistleblowers also have the option of leaving an email address before sending the report or complaint to make it easier to keep up to date with the progress of the processing. This email address is not visible to the responsible complaints officers.
If reports or complaints are submitted by e-mail to legal@wisplinghoff.de, they will all be received by legal staff in the legal department and their receipt will be acknowledged within one week.
Review of the reports/complaints
All reports and complaints in the digital reporting channel or via e-mail are reviewed for their seriousness and relevance to the scope of the complaint procedure by the same complaints officer who has received the respective report/complaint.
If the available information is not sufficient for the review, the responsible complaints officer will, as far as possible, contact the person who provided the information in order to clarify possible questions or to request further information.
Clarification of the case
Whistleblowers will be informed in the respective reporting channel by the legal staff of the legal department about the outcome of the review of their report/complaint.
(1) In the event of a rejection, reasons will be given and the person providing the information will be informed immediately.
(2) If the report/complaint is followed up, the person, who provided it, will be, as far as possible, actively informed about the progress of the investigation. If the available information is not sufficient for a further investigation, the legal staff of the legal department will immediately contact the person who provided the information to clarify the matter. This discussion also serves to identify whistleblower‘s expectations regarding possible preventive or remedial actions.
(3) If a violation of human rights and environmental standards has already occurred, is imminent or appears possible in own business area or supply chain, appropriate preventive and remedial measures will be taken immediately. The aim of these measures is to avoid a violation of protected legal positions or to end or minimize violations of protected legal positions that have already occurred. The whistleblower will generally receive feedback no later than three months after acknowledgment of receipt of the report, which includes notification of planned and already taken follow-up measures and the reasons for these. The implementation of the introduced measures is monitored. The achieved result is, as far as possible, evaluated together with the whistleblower.
Documentation and storage
The respective complaint process is documented. It is kept for at least seven years from its creation.
How do we protect the identity of whistleblowers?
The Privatärztliche Laborgemeinschaft treats the protection of whistleblowers as an important part of an effective complaints procedure and does not tolerate any discrimination or punishment for lawfully using the complaints procedure. To protect whistleblowers, the following measures have been implemented:
- All reports and complaints will be treated professionally and confidentially.
- Incoming reports and complaints are processed by trained complaints officers.
- Whistleblowers are free to submit an open or anonymous report.
- The whistleblowers cannot be traced through the external reporting channel.
- The reporting channel complies with the requirements of the law for better protection of whistleblowers (Whistleblower Protection Act – HinSchG), BGBI. I 2023, No. 140.
- Data protection regulations are always adhered to.
Indications of discrimination or punishment of those who provide information are reviewed and investigated with the utmost seriousness. We ask that you submit an official report via our designated reporting channels if you become aware of any retaliation against whistleblowers.
Effectiveness review
The complaints procedure is reviewed annually and on an ad hoc basis. If a need for improvement is identified, the complaints procedure will be adjusted.