Rules of procedure of igus GmbH

for the complaint handling according to the Supply Chain Act

Version I, Issue 01. January 2024

1. Objectives and scope of the complaint handling

The complaint handling of igus GmbH enables all potentially affected persons to point out risks to human rights or the environment and breaches of duty that have arisen as a result of the economic activities of igus GmbH in its own business area or in the business area of a supplier along the entire supply chain.

igus takes the requirements of the Supply Chain Act seriously and it is our aim to identify potential misconduct along the supply chain at an early stage and to initiate the appropriate measures.

igus achieves this in particular by allowing information about possible violations in connection with the Supply Chain Act to be reported to us and by consistently following up on them.

All employees and persons along our supply chain can notify igus of risks to or violations of human rights or the environment via the complaint handling set up by igus.

It is ensured that the notification can be submitted anonymously and confidentially. This gives igus the opportunity to recognise risks at an early stage and, in the best case, to resolve them before people or the environment are harmed.

2. Procedure for making comments/reporting compliance violations

There are various internal channels for reporting a compliance violation (e.g. notification of superiors or employee representatives) and the igus whistle-blower system is available for both internal and external reports. This can be used without restriction by anyone in our supply chain.

Compliance violations can be reported worldwide, around the clock, in various languages and free of charge with just a few clicks via our online reporting system Whistle-blower System (reporting-channel.com).

When submitting a report, the thematic focus should be stated in relation to the risks to human rights and the environment or breaches of duty within the meaning of § 2 Sections 2 and 3 of the Supply Chain Act.

The human-rights-related prohibitions include in particular

• Child labour (as a rule, the employment of children under the age of 15 is prohibited)
• Forced labour
• Slavery, sexual exploitation
• Failure to comply with health and safety regulations according to the law of the place of employment
• Withholding of appropriate wages
• Use of torture or humiliating treatment
• Freedom of association
• Any act or omission that is capable of impairing a protected legal position in a particularly serious manner and of which the unlawfulness is obvious.

The environment-related prohibitions include in particular

• Ban on the manufacture of compounds containing mercury
• Prohibition of improper treatment of mercury waste
• Ban on the production and use of certain chemicals and persistent organic pollutants
• Prohibition of non-environmentally sound handling, collection, storage and disposal of waste
• Contamination of soil, water, air and excessive water consumption
• Any act or omission that is capable of impairing a protected legal position in a particularly serious manner and of which the unlawfulness is obvious.

3. Receipt and initial assessment of reports

As part of an initial assessment, HR determines whether the report is relevant to human rights or the environment or breaches of duty and whether the report submitted is correct. This is followed by a risk assessment of possible consequences, for example using a risk matrix.

The person providing the information receives prompt feedback that the information has been recorded. Furthermore, interim status reports on each processing step and on the final result are sent to whistle-blowers via the portal in a protected environment.

4. Examination procedure

If relevance and initial suspicion are confirmed, we initiate an internal investigation procedure as quickly as possible to clarify the facts. The notification will be checked in detail.

5. Implementation of necessary measures

Once the investigation has been completed, igus checks whether measures are required to eliminate, minimise or prevent the infringement in future. To this end, we analyse the specific need for correction and improvement. Part of this analysis also includes taking into account the expectations of the group of people affected by the breach. Necessary measures may be purely internal measures in our business division, such as process adjustments, new guidelines or improved training concepts. However, measures with and towards third parties may also be necessary. The implementation of the measures is monitored appropriately and their effectiveness is closely scrutinised in detail in small process steps.

6. Documentation

All reports, investigation activities and results are documented and archived in defined locations. They are stored in accordance with the relevant legal requirements and data protection periods. Viewing and access rights are strictly regulated. In addition, where required by law, we inform all data subjects about the investigations carried out and the personal data processed in this context.

7. Risk analysis and reporting

The findings from the processing of reports are taken into account in the risk analysis. An annual report is prepared and published on the number and handling of reports. In addition, ad hoc reports are submitted to management.

8. Effectiveness test

We review the effectiveness of all the systems and processes described above in connection with our complaint handling on an ad hoc basis, at least, however, once a year.

9. Protection of whistle-blowers

Indications of possible risks to human rights or the environment or breaches of duty are of great value to igus and our supply chain.

For this reason, anonymous dialogue is possible throughout the entire complaint handling. The confidentiality of the anonymous exchange is guaranteed at all times. The IP address is not logged. The following procedures have been introduced for the technical protection of the whistle-blower:

• Transport encryption: all data stored in the databases of Whistle-blower System (reporting-channel.com) is encrypted.
• Rule-based deletion routines support data-protection-compliant deletion.
• Regular IT security audits monitor system security.

By submitting a report in the igus complaint handling, the whistle-blower is not threatened with any negative consequences. The confidentiality of the exchange is ensured at all times (see Section 3 and is also guaranteed internally by suitable measures.

10. Contact

If you have any comments or suggestions regarding our complaint handling, please do not hesitate to contact our HR department on +49 2203 9639-151.