Rules of procedure of SICK AG for the complaints procedure pursuant to the German Act on Corporate Due Diligence in Supply Chains

Scope of the procedure

Protecting and respecting every individual is a top priority for SICK AG and an indispensable part of our entrepreneurial responsibility. Therefore, compliance with the due diligence obligations arising out of the LkSG is a matter of course for us. However, despite our compliance management, individual cases of misconduct cannot be excluded.

SICK AG has implemented a complaints procedure in accordance with section 8 of the LkSG. This procedure allows individuals to report human rights-related and environment-related risks and the violations of human rights and environmental obligations that arise out of the economic activity of SICK AG in our own business operations (including at our Group companies) or in the business operations of a direct or indirect supplier.

The complaints procedure is open to all persons potentially involved in it within and outside of our business operations, for example, to employees of SICK AG and its Group companies or to employees of direct and indirect suppliers of SICK AG and its Group companies. Reports can be submitted not only by the parties that are directly involved but also by third parties, for example, acting on behalf of the parties directly involved.

Responsibility for the complaints procedure at SICK AG

The Human Rights Officer of SICK AG is responsible for implementing the complaints procedure in accordance with section 4 (3) sentence 1 of the LkSG (“Complaints Body”). The Human Rights Officer is the Chief Compliance Officer of SICK AG. He is supported in the handling of the complaints by a team of case managers (“Compliance Team”).

Reporting channels

Human rights-related and environment-related risks and violations of human rights and environmental obligations can be reported, anonymously if preferred, via the SICK Integrity Line of SICK AG. The SICK Integrity Line is a web-based platform that can be also used to report other forms of misconduct affecting our company or a company of the SICK Group or the wellbeing of SICK employees and third parties.

Communication via the SICK Integrity Line is confidential and protected. The contents of the reports are investigated by the Compliance Team. The SICK Integrity Line is available around the clock in many languages.

Reports to the SICK Integrity Line can be submitted on the following website: https://sickag.integrityline.com

In the USA and Canada, confidential and protected reports can also be submitted to the SICK Integrity Line by telephone. The following country-specific telephone numbers can be used for this purpose:

Canada: +1 866 204 1940 – Please enter the following identification code: 11477
USA:        +1 833 211 3671 – Please enter the following identification code: 11477

Such reports can be also submitted to the Compliance Team of SICK via the following reporting channels:

E-mail: compliance@sick.de
Phone: +49 (0)7681-202-3276

Post:
SICK AG Compliance / LGC
Erwin-Sick-Str. 1
79183 Waldkirch Germany

They can furthermore be submitted in person to the Human Rights Officer (please make an appointment through the aforementioned reporting channels).

The complaints procedure in detail

When a report is submitted via the above reporting channels, a confirmation of receipt must be sent out to the whistleblower within seven days. The Complaints Body checks if any human rights risk or environmental risk has arisen or if any human rights-related or environment-related obligations have been violated. The Complaints Body also checks if there has been any other form of misconduct, such as any violation of laws or internal regulations. If expedient or necessary, the Complaints Body will discuss the contents of the complaint and the underlying facts with the whistleblower.

The Complaints Body conducts an internal investigation of the report in accordance with the applicable laws and internal rules and in consideration of the interests of all the parties involved. The investigation must be conducted without any undue delay and major interruptions. The whistleblower may inquire at any time about the progress of the investigation and shall receive an update on the investigation and the follow-up actions, if any, no later than three months as of receipt of the report. When the update is provided, all rights of the parties involved must be protected. No later than upon the completion of the investigation, the whistleblower will be informed to the legally permissible extent about the investigation result. Investigations conducted within the scope of the complaints procedure must be completed within an appropriate time frame. We endeavor to complete investigations within six months.

The Complaints Body charged with the complaints procedure by SICK AG guarantees an impartial procedure because the Human Rights Officer of SICK AG is independent and not bound by instructions. This also applies to all members of the Compliance Team who are charged with investigating a report. In addition, the Human Rights Officer and all members of the Compliance Team are under an obligation of secrecy.

All activities that are carried out within the scope of the complaints procedure are in line with the applicable laws. Alle reports will be investigated objectively, reliably and with the due care and diligence. All persons who are the subjects of an investigation must be treated in a fair and respectful manner. This applies especially during interviews and other personal contacts. Prejudgment and biased actions must be avoided. The presumption of innocence applies for all persons who are the subjects of internal investigations.  

The Complaints Body is responsible for the legal evaluation of the case. The company defines appropriate actions to remedy and prevent misconduct in the business operations of SICK AG (and its Group companies) or at direct and indirect suppliers. Such actions may include, for example, appropriate civil action or labor-law action or the involvement of an authority. Changes to work processes and business processes as well as to organizational rules and rules of conduct are also possible.

Protection of whistleblowers against discrimination and retaliation

The Human Rights Officer and the members of the Compliance Team are obligated to protect to the best of their ability the confidentiality of the whistleblower’s and third parties’ identities that are disclosed in a whistleblower’s report.

The members of the Compliance Team charged with the investigation of the reports as well as all other employees involved must handle the investigations in strictest confidence. Insofar as it is necessary to involve external experts, such experts must be under a professional obligation of confidentiality or agree by contract to observe confidentiality.

SICK does not tolerate any retaliation against whistleblowers who voice their concerns in good faith. Discriminating against and punishing such whistleblowers is forbidden. Upon receiving reports of retaliation against whistleblowers, the members of the Compliance Team must inform the Human Rights Officer without delay. He will inform the company management and recommend appropriate action.

The reporting system must not be used for false accusations.

Data Protection

In general, whistleblowers can submit reports – insofar as legally permissible – without including any personal data. However, within the framework of the investigation whistleblowers can voluntarily disclose personal data, particularly information about their identity, first name and surname, country of residence, phone number, or email address. Compliance with legal retention periods and data protection regulations is guaranteed.

Effectiveness of the complaint procedure

The effectiveness of the complaints procedure will be reviewed annually and on a case-by-case basis where the company expects a substantially altered or substantially greater risk exposure in its own business operations or at the direct supplier, for example, due to the launch of new products, projects, or a new business segment.

These Rules of Procedure come into effect as of January 1, 2023.

Waldkirch, December 19, 2022

SICK AG

The Executive Board
Dr. Mats Gökstorp (Chairman), Feng Jiao, Ulrike Kahle-Roth, Nicole Kurek, Dr. Niels Syassen, Markus Vatter, Dr. Tosja Zywietz