Rules of procedure for the SIEMPELKAMP Group's complaints system for its own business area and supply chains

1.1 Who is responsible for complaints relating to human rights and environmental issues?

The Compliance department is responsible for setting up this complaints procedure. If you have any further questions about the complaints procedure and the corresponding processes, please contact the Compliance department (hereinafter referred to as the "Complaints Office") of the SIEMPELKAMP Group at compliance@siempelkamp.com.

1.2 Who can submit complaints? Which complaints are processed?

This complaints procedure can be used to report potential risks with regard to human rights and environmental concerns or breaches of duty (hereinafter referred to as "incidents").

This procedure is aimed (in addition to the existing internal reporting channel) at the company's own employees and employees of direct or indirect suppliers. In addition, however, all other potentially affected parties and, if applicable, their representatives (hereinafter referred to as "whistleblowers") should also be able to use this procedure.

1.3 Do you have to fear consequences in the event of a complaint?

SIEMPELKAMP takes all complaints seriously. Whistleblowers should not face any disadvantages as a result of complaints. This applies regardless of whether the whistleblower is himself affected by the reported incident. The SIEMPELKAMP Group and the relevant departments will not tolerate any negative consequences as a result of complaints and, in individual cases, will point out specific measures that employees or suppliers must expect if whistleblowers are exposed to negative consequences. Whistleblowers are also encouraged to report any negative consequences following a complaint.

The processing of the complaint and the corresponding investigation will be carried out fairly, objectively and in a confidential manner. The applicable data protection regulations are taken into account.

1.4 How are employees protected?

To protect employees, the complaints office anonymizes the information and its description in individual cases of particularly sensitive complaints or incidents. It should not be possible to identify individuals during further processing. Anonymization does not take place if the complaints office comes to the conclusion during the initial assessment that a serious violation of human rights or environmental concerns is to be feared and anonymization could hinder the processing of the complaint.

1.5 Is the complaints office independent?

The complaints office is independent of instructions when performing its tasks (including with regard to determining the scope of the audit and reporting on audit results) and evaluating its audit results.

1.6 How are barriers to accessing the complaints procedure avoided?

The SIEMPELKAMP Group has taken the following measures in particular to minimize access barriers to the complaints procedure:

The digital complaints system for the German Supply Chain Due Diligence Act (LkSG) is a website-based complaints channel with an online input mask that is easy to find,
information about and access to the complaint channels is provided in several languages, at least in German and English, and
the procedure is not associated with any costs.
Employees of the Siempelkamp Group also have access to the already established internal reporting system and receive training in this area.

2. Details of the complaints procedure

2.1 Submitting a complaint:

Whistleblowers have the option of submitting complaints anonymously or with contact details via the following various channels

E-mail adress: compliance@siempelkamp.com
Website: www.siempelkamp.com

For subsequent contact when using the website as a complaint channel, it is necessary to enter an email address. Whistleblowers can use email addresses that do not allow SIEMPELKAMP to identify them personally. Complaints are not evaluated or processed as a matter of priority, but are generally evaluated according to their receipt and, if applicable, their potential impact.

2.2 Documenting the input

Every report or complaint made through the above-mentioned channels is recorded and documented by the complaints office. This applies not only to the receipt, but also to the entire processing period and the statutory retention period.

2.3 Confirmation of receipt to whistleblower

Upon receipt of the complaint, the responsible complaints office will send an acknowledgement of receipt to the whistleblower. The complaint channel used by the whistleblower will be taken into account. If an acknowledgement of receipt cannot be sent, for example because the whistleblower has not provided any contact details, no acknowledgement of receipt will be sent.

2.4 Communication to the whistleblower

The Complaints Office will endeavor to provide the first feedback to whistleblowers as quickly as possible, but at the latest within three months of confirmation of receipt. The Complaints Office will inform whistleblowers about the measures taken. The Complaints Office will endeavor to provide final feedback to whistleblowers regarding the incident within six months of confirmation of receipt. In cases where a more comprehensive or thorough investigation is required, feedback may be provided at a later date.

2.5 Checking admissibility

The complaints office checks the admissibility of the complaint and its relevance to the LkSG. A complaint is admissible if it contains sufficient and plausible information about a potential incident so that further processing is possible. A complaint is relevant if the review shows that there are indications of human rights or environmental risks in the supply chain or in the company's own business area. Furthermore, a complaint is relevant if it involves potential violations of the provisions of the LkSG caused by the company itself or its direct or indirect suppliers.

This results in the following three cases:

Case 1: Complaint is admissible and LkSG relevant -> Initial assessment begins
Case 2: Complaint is not admissible -> The whistleblower is informed.
Case 3: Complaint is not relevant to the LkSG -> The information may have to be investigated by other departments due to other relevance for the SIEMPELKAMP Group.

2.6. Performing initial assessment

The complaint will be investigated further if it is conclusive. The potential tip-off will be followed up if, according to the documents provided, in particular the description of the facts provided by the whistleblower, the evaluation of the documents submitted by the whistleblower in the individual case and other readily available information, a human rights or environmental risk or a violation of the provisions of the LkSG is likely.

No excessive requirements are placed on the assumption of conclusiveness, for example that clear evidence must be available. However, the suspicion must be based on concrete, possible or probable facts and indications. As soon as this is the case, the process either continues with step 2.7 and a conciliation procedure is carried out or with step 2.8 and the complaint is investigated further internally.

2.7 Carrying out arbitration proceedings

The SIEMPELKAMP Group can offer an amicable settlement procedure with the aim of making amends. The prerequisite for this is that the whistleblower is also the person affected by the potential violation. In such a conciliation procedure, a joint solution is found to resolve the complaint. If the whistleblower accepts the offer of mediation, the complaints office works with the relevant departments to find a solution with the whistleblower with the help of a neutral and mediating third party (e.g. an ombudsman) and initiates corresponding measures. However, the LkSG does not provide for an obligation to conduct a mediation procedure. For example, redress is also not mandatory.

If the conciliation procedure is not carried out or no solution is found, the provisions in 2.8 apply and the complaint is investigated further internally.

2.8 Clarifying the complaint internally

In principle, the complaints office involves other interest groups in the internal clarification process:

a) The central SIEMPELKAMP risk management is involved, if necessary, to investigate the complaint for business risks.

b) The complaints office sends an investigation request to the responsible departments, which are requested to carry out the following further process steps to clarify the complaint:

Defining investigation steps: The departments define the necessary investigative steps to follow up the complaint and conclusively determine the facts of the case.
Defining measures for investigation: The departments themselves define the appropriate measures required to determine the facts in individual cases.
Performing investigation steps: The defined investigation steps are carried out as quickly as possible.
Coordinating with other departments: If necessary, other departments will be involved.
Evaluating the facts: The specialist departments evaluate the facts on the basis of the available information.
Documenting feedback: The result of the factual assessment is reported to the internal coordination office and documented.
Derivation of measures in coordination with the relevant specialist departments: If the information is confirmed, the specialist departments formulate the necessary measures.

2.9 Taking action

If the investigation of the complaint reveals that there is a risk or a violation, appropriate preventive or remedial measures are taken in consultation with the relevant departments (see above).

The specific design, implementation and review of the implementation of the measures is the responsibility of the respective department.

2.10 Final information to the whistleblower

The whistleblower is informed transparently about how their complaint has been dealt with and what measures have been taken.