Rules of procedure for the complaints procedure under the German Supply Chain Due Diligence Act


KODi supports people in acting more courageously and responsibly and takes responsibility for strengthening recognised human rights. For this reason, it is of great importance for KODi to fulfill the human rights and environmental due diligence obligations under the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz; LkSG). Violations can have serious consequences for our company, our employees, our business partners and other affected parties. That is why we must and want to recognise them at an early stage in order to initiate appropriate countermeasures and avert potential damage.

An important part of our due diligence obligations is the establishment of an effective complaints procedure through which information on violations of human rights and environmental risks can be passed on. We have set up a complaints procedure through which information on human rights and environmental risks or violations can be submitted. Fast, transparent processes and the confidential and professional handling of reports by internal experts form the basis of this system.

The most important information on the complaints procedure is presented below in an understandable, comprehensible and transparent manner:


What is the complaints procedure under the LkSG for?

The complaints procedure enables any individual or group to submit appropriate complaints or information to KODi. This creates an early warning system that alerts KODi to human rights and environmental risks. All indications of possible violations of laws and/or regulations, including human rights or environmental risks or violations relating to the company’s own business area and along the entire supply chain, can be reported.

It is also possible to report suspected cases so that damage can be averted or minimised immediately.


Who can submit complaints and/or reports?

Any person domestic or abroad can submit complaints and/or reports.

How can complaints and/or reports be submitted?

We process complaints and/or reports in confidence with the law firm Kreutz & Partner from Xanten, which has been with us for many years and therefore also knows the internal processes at KODi well. As a professional law firm for SMEs with experienced lawyers, every complaint and/or report can be handled well there in the interests of all parties involved. In particular, confidential and independent processing of complaints and/or reports is guaranteed.

The law firm Kreutz & Partner can be contacted in its function as a KODi complaints channel at:


Phone:            02801-771033

Address:        Kreutz & Partner Rechtsanwälte / KODi-Hinweisgeber / Sonsbecker Str. 61 / 46509 Xanten

All channels ensure that reports are handled confidentially.


Who processes the complaints and/or reports?

The complaints and/or reports are processed impartially, independently, without instructions, confidentially and within a reasonable amount of time by Kreutz & Partner as well as by the supervisors or known contact persons. The confidentiality of the identity of the whistleblower and the other persons named in the report is maintained throughout the entire process.


How are whistleblowers protected?

KODi ensures the confidentiality of every report. Attempts at intimidation and reprisals are not tolerated. If the impression arises that there is a threat of intimidation or reprisals due to a tip-off, this should be reported to the complaints office. Intimidation or reprisals will be investigated in accordance with the procedures outlined and, if necessary, investigated further.

If whistleblowers who are employees of a direct supplier are affected, KODI will endeavor to make appropriate contractual arrangements with the supplier.


What happens next in the procedure?

Once a complaint or tip-off has been received, the person who made the tip-off will receive confirmation within one week.

The complaints office will then check whether there is sufficient information to examine and investigate the matter. If this is not the case, the complaints office will, if necessary, contact the person who made the report in order to obtain further information. If the necessary information is not available and no contact can be made, the case will be closed.

The complaints office will investigate the case thoroughly itself. If necessary, the complaints office clarifies the facts of the case with the person who provided the information. If possible, further information will be requested. If, after clarification of the facts, discussion and investigation, the complaints office is convinced that there are no human rights or environmental risks or violations of human rights or environmental obligations in its own business area or with suppliers, the case will be closed.

If the investigation reveals that there are human rights or environmental risks or breaches of duty in the company’s own business area and at suppliers, a proposal for further measures is drawn up. Preventive and remedial measures are given particular consideration. The person who provided the information is included in this process, if possible and appropriate.

The proposed solution is implemented by the complaints office and the person who provided the information receives notification of the conclusion of the complaints procedure, provided that contact can be made. The time required for processing can vary greatly and ranges from a few days to several months, depending on the case.