Rules of Procedure
on the Complaints Procedure in the Event of Violations of the Act on Corporate Due Diligence Obligations for the Prevention of Human Rights Violations in Supply Chains (LkSG)
The purpose of these Rules of Procedure is to provide a transparent presentation of the company's own complaints procedure within the meaning of Section 8 (2) of the LkSG of KUKA AG and its affiliated companies within the meaning of Section 15 of the German Stock Corporation Act (AktG) with their registered offices in Germany (hereinafter "KUKA"). The purpose of the complaint procedure is to enable persons to point out human rights and environmental risks as well as violations of human rights-related or environmental due diligence obligations under the LkSG that have arisen as a result of KUKA's economic activities in its own business area or as a result of the actions of a supplier.
1.2 Scope of application
- External employees, e.g. temporary workers, employees of external service providers
- Business partners, e.g. suppliers, customers or cooperation partners
- Internal whistleblowers
- Other third parties
2. Complaint procedure
External whistleblowers can either contact the Compliance Officers or complain their concerns anonymously to the Ombudsperson, who is not employed by KUKA and is therefore independent. Contact details are publicly available on the company's website.
Internal whistleblowers have access to the communication channels listed in the Corporate Compliance Manual. These are the same complaining channels that can be accessed by external parties, supplemented with the option of contacting their manager and the HR department.
Whistleblowers can also submit their complaint to KUKA through a web-based platform via the following link:
Furthermore, it is possible to submit the complaint by telephone by calling the telephone numbers indicated on the above platform.
After submitting the complaint, whistleblowers receive - if desired, anonymized - access data that serve as an access key to the web-based whistleblowing management system. This enables whistleblowers to access the whistleblowing management system at any time and to track the status and processing progress of their complaint and, if necessary, to answer queries from the company and add further information.
After sending the complaint, the responsible persons within the KUKA Compliance Organization will be informed about the existence of a new complaint.
KUKA will acknowledge receipt of a complaint within five business days.
Each complaint will be carefully reviewed. If it is plausible, it is forwarded to the responsible Compliance Officer. This officer works independently and impartially to clarify the facts. The investigation is conducted confidentially. Compliance Officers may conduct confidential discussions with employees, contractors or others they deem relevant to the investigation.
After all findings of the investigation have been reviewed, a determination will be made as to whether a violation has occurred and, if so, corrective action will be taken. The whistleblower will be notified accordingly no later than 3 months from receipt of the acknowledgement of receipt.
3. Confidentiality and protection of disadvantages
KUKA is committed to maintaining confidentiality and protecting the interests of whistleblowers. It is in the interests of the company to uncover and remedy grievances.
KUKA protects the anonymity of whistleblowers throughout the entire process of handling a complaint, provided that the complaining person indicates that he or she wishes to remain anonymous. No measures will be taken to find out their identity.
Whistleblowers who complain possible compliance violations and provide information about human rights and environmental risks as well as violations of human rights-related or environmental due diligence obligations to the best of their knowledge and in good faith do not have to fear any adverse measures by the company as a result of the complaint. KUKA reserves the right to take legal action or disciplinary measures against whistleblowers in the event of recognizable misuse of the KUKA whistleblowing management system.
KUKA also protects the rights of the accused person. The presumption of innocence under the rule of law applies until proven otherwise.
4. Review and improvement
KUKA will conduct regular and ad hoc reviews and continuous improvements of the complaint procedure.