Rules of Procedure

Rügenwalder Mühle's RULES OF PROCEDURE for the complaints process in accordance with the Supply Chain Due Diligence Act (LkSG)

1. Motivation and objectives
According to the German Supply Chain Due Diligence Act (LkSG), companies are obliged to observe human rights and environmental due diligence obligations in their supply chains in an appropriate manner, with the aim of preventing or minimising human rights or environmental risks or putting a stop to the violation of human rights or environmental obligations. 

Recognising and respecting human rights is a top priority for Rügenwalder Mühle. As part of our business activities and corporate responsibility, we are fully committed to respecting human rights.
The complaints process enables those directly affected and also those who have knowledge of possible or actual violations to inform Rügenwalder Mühle of possible risks or abuses.

2. Reporting office
The digital reporting system, which is available online at any time at, allows anyone, in particularemployees, businesspartners and other persons, to submit reports anonymously. The digital reporting system enables the authorised reporting office to receive and follow up on reports while maintaining confidentiality and integrity at all times.

It guarantees impartiality, acts independently and is not bound by instructions.

The reporting office is part of the Legal & Compliance Department at Rügenwalder Mühle. The officers with access to the reporting system are:
· Human rights officer according to LkSG 
· Reports officer 

The Rügenwalder Mühle reporting office is responsible for receiving and reviewing reports of legal or regulatory violations affecting the companies in the Group, their business partners or suppliers along the entire supply chain.
The reporting office decides on corrective measures if the report of a possible violation appears plausible. 
The processing and storage of reports are subject to German law, unless other standards are mandatory. 
The reporting office acts as an internal reporting point for the following companies: 
· Rügenwalder Mühle Carl Müller GmbH & Co. KG 
· RMG Betriebs-GmbH & Co. KG 

As part of this role, the reporting office processes qualified reports concerning those companies. If a report proves to be justified, the reporting office will decide what follow-up measures to implement. Reports that contain deliberately untrue information are not subject to the requirement of confidentiality and may be subject to fines or criminal prosecution.

3. Process of the complaints procedure
Complaints may be lodged by affected parties and third parties (Section 8(1) sentence 1 LkSG) as well as by potential participants in the supply chain (Section 8(4) sentence 2 LkSG). The complaints procedure is available internally and externally.

Step 1: Acceptance
Upon receipt of the complaint from the whistleblower, the reporting office checks whether it falls within the scope of the complaints procedure. If it does, the complaint is accepted.
If it does not fall within the scope of the complaints procedure, the complaint is referred to the relevant department at Rügenwalder Mühle.
The whistleblower receives confirmation of receipt within 14 days and, if applicable, a reason for the referral.

Step 2: Evaluation of the report
Once the report has been received, it is assessed and categorised as reported misconduct (triage) or as a risk for the whistleblower and relevant interested parties (disadvantages), so that appropriate measures can be taken in the next step.

Step 3: Taking action
The reporting office investigates the report.
The contact person discusses the facts of the case with the whistleblower with the aim of gaining a better understanding of it. The whistleblower’s expectations with regard to possible preventive or remedial measures are also discussed.
A proposal for remedial action is developed in dialogue with the whistleblower. The agreed remedial measures are implemented and followed up.
The whistleblower may also be offered an amicable dispute resolution procedure, in which case the parties involved attempt (with the help of a neutral, mediating third party) to find a mutually acceptable solution together, instead of obtaining a decision via the official complaints procedure.
The whistleblower may also be required to provide follow-up information and answers to further questions.
Step 4: Conclusion
The complainant receives feedback on the subject of the complaint within 90 days of submitting his/her complaint. Such feedback may take the form of a recommendation or a decision.
Appropriate preventive and remedial measures are taken to resolve the subject of the complaint based on the reported facts in order to bring the proceedings to a mutually satisfactory conclusion. 
The effectiveness of the procedure is reviewed annually and on an ad hoc basis. If necessary, adjustments are made to the process or corrective measures are taken.

4. Contact person for the complaints procedure

The person entrusted with handling the complaints procedure must offer a guarantee of impartiality and be subject to a confidentiality obligation. At Rügenwalder Mühle selected employees have been entrusted with processing complaints as reporting officers.

5. Confidentiality and data protection

Rügenwalder Mühle takes precautions to ensure that complainants’ identity is kept confidential and their personal data is protected. During the procedure, it is possible to use a secure tool that also allows anonymous communication (digital reporting system).

The reports are documented in the digital reporting system and deleted in accordance with the statutory deletion periods. For reports that fall under the Whistleblower Protection Act, that period is three years after the completion of the proceedings. For information that falls under the scope of the Supply Chain Due Diligence Act, a period of seven years applies from the documentation drafting data.

6. Ensuring protection against discrimination or punishment
Rügenwalder Mühle does not tolerate retaliatory measures against anyone who raises concerns in good faith. Protection against retaliatory action also extends to those involved in the investigation of such concerns and, where appropriate, to other persons involved.