Regulamin procedury zgłoszeń
In everything we do, the manner in which we do it has always shaped us:
Simply, reliably, and responsibly.
We abide by rules and promote a culture at ALDI in which we act reliably and take responsibility - everyone, regardless of hierarchy and their position in it, internally and in our dealings with our business partners.
For us, compliance with laws and regulations represents the basis of economically responsible conduct. Above and beyond this, however, we also have special requirements for acting with integrity.
This whistleblowing system is part of our Compliance Management System, and, among other things, it enables you to report - even anonymously - any compliance violations at the ALDI Nord Group.
A. Scope of ApplicationThese Rules of Procedure apply to the collection and processing of information on potential violations of rules or misconduct in the German companies of the ALDI Nord Group of
Companies and the associated supply chains. The whistleblowing procedure described in these Rules of Procedure thus includes the complaint procedure pursuant to Section 8 of the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz).
The processes described in these Rules of Procedure apply provided that the reporting channels described in section B II are used.
B. Submission of Reports
I. Admissibility
Any person - regardless of whether they are an employee1, a customer, a supplier or a third party - may submit a report on potential violations of rules or misconduct in the companies included in the scope of these Rules of Procedure and the associated supply chains.
1 The use of the masculine form when naming persons or functionaries in the following text does not imply a
gender-specific definition. Members of all genders are to be addressed equally.
II. Reporting Channels
Information about potential violations of rules or misconduct can be forwarded via the
following channels to ALDI Einkauf SE & Co. oHG, which has also been appointed by all
other German companies of the ALDI Nord Group to implement the whistleblower procedure
in this regard:
Electronic Whistleblowing System2
www.bkms-system.com/aldi-nord
Communication and the exchange of documents are conducted in a confidential and protected manner via a dedicated postbox.
- Direct contact by e-mail to compliance@aldi-nord.de
Post
ALDI Einkauf SE & Co. oHG - Abteilung Compliance, Eckenbergstraße 16 B, 45307 Essen
Regardless of the reporting channel, reports can be submitted anonymously or bearing thename of the person submitting the report. All reports - whether anonymous or not - will be treated with the utmost confidentiality and personal data will be protected.
2 The eelectronic whistleblowing system is only available to the extent that the company concerned participates
in it.
III. Subject Matter of the Report
It is possible to report the following:
- Actual or alleged violations of laws and other directly applicable legal provisions or
other binding (including internal) regulations - Human rights and environment-related risks as well as violations of human rights orenvironment-related obligations due to commercial activities in one's own business sector or those of a supplier in accordance with the German Supply Chain Due Diligence Act
Any product-related and/or service-related customer concerns and complaints will not be
handled and should be submitted via the customer contact form
https://www.aldinord.de/tools/kontakt.html
IV. Content of the Report
The following information will help in the handling of a report:
Description of the facts in chronological order, if possible, including the following
information:
- What happened?
- Where did it happen? When did the incident occur? Is the incident still ongoing?
- Who is/are the person(s) or group(s) affected or harmed? What is the impact of the damage?
- Who could be responsible for this incident?
- Which legal provision or regulation has been violated? What is the commercial
connection to the ALDI Nord Group of Companies? - What supporting documentation is available (photos, videos, documents,
witnesses, etc.)? - What are the expectations regarding possible corrective or preventive measures?
- What is the specific objective of the complaint?
- Wurde jemand anderes bereits über den Missstand informiert?
Information that is as specific as possible facilitates and accelerates the appropriate handling of a report and is therefore of assistance in the formulation of a report. However, providing information on the aforementioned points is not a prerequisite for the handling of a report.
C. Process Description of Procedure I. Acknowledgement of Receipt If it is possible to make contact, receipt of the report will be acknowledged in writing or electronically within seven days, depending on the type of reporting channel chosen. The person providing the report will be informed to an appropriate extent about the proceedings as well as the routine timeline of the procedure.
II. Investigation of the Report and Clarification of the Facts After receipt of a report, the Compliance Department of ALDI Einkauf SE & Co. oHG will check it for plausibility and validity to determine whether, based on the information provided, violations of rules or risks or violations relevant under the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz) can be considered as permissible reportable matters. If necessary, the facts of the case will already be discussed with the whistleblower at this point, if it is possible to contact the whistleblower.
If - even after a consultation with the whistleblower - no admissible reportable matter exists or the suspicion of a violation of the rules or of a risk relevant under the Supply Chain Due Diligence Act or of such a violation is evidently ruled out, the procedure will be terminated. The whistleblower will be informed of this - if contact is possible.
If a violation of the rules or a risk relevant under the Supply Chain Due Diligence Act or such a violation comes into consideration, the report is forwarded to the respective authority responsible, which further discusses the facts with the whistleblower - if necessary and technically possible - and then examines which investigation or clarification measures (socalled follow-up measures) are necessary. These may include, for example, internal investigations as well as discussions or audits to be conducted with suppliers. In addition, the extent to which legal and actual further measures may or should be taken at this stage is examined on the basis of the information provided.
The whistleblower has the opportunity to provide additional information, facts or evidence at any time during the investigation of the matter.
III. Possible Outcomes of the Procedure
Depending on the outcome of the investigation of the matter, corporate decisions are taken to deal appropriately with any violation or any risk that may have been identified. This can lead to the dismissal of employees or the termination of business relations with suppliers.
IV. Involvement of the Whistleblower Every report is taken seriously. Therefore, the whistleblower is always informed about the processing of the matter, the status of the proceedings and the outcome, provided that it is possible to contact the whistleblower. Within the scope of this information, however, conflicting legally protected interests of other persons and companies must also be taken into account, e.g. data protection requirements.
V. Duration of the Procedure The duration of the procedure depends on the scope and complexity of the report.
High priority is given to the processing of reports and an investigation is conducted promptly.
Depending on the scope and complexity, a professional examination of reports can take a few days, but can also take several months in some cases.
VI. Costs of the Procedure The whistleblower may make use of the whistleblowing procedure described in these Rules of Procedure at no cost.
Any costs and expenses incurred by the whistleblower in connection with the use of the whistleblowing procedure will not be reimbursed and must be covered by the whistleblower.
In particular, travel expenses and costs for legal advice, if any, will not be covered.
Procedural Principles I. Confidentiality The employees entrusted with the processing of reports shall treat the information obtained in a confidential manner with respect to other persons. The identity of whistleblowers will not be disclosed if that is their wish and if this is legally possible.
Any statutory disclosure and reporting obligations remain unaffected by this.
II. Protection of Whistleblowers Whistleblowers who report possible violations of rules, or risks and violations that are relevant under the Supply Chain Due Diligence Act, to the best of their knowledge and in good faith, shall not be subject to reprisals or any other measures detrimental to them by companies included in the scope of these Rules of Procedure as a result of making the report.
The companies included in the scope of these Rules of Procedure shall also endeavour to ensure that suppliers do not discriminate against whistleblowers as a result of a report submitted to the best of their knowledge and in good faith in accordance with these Rules of Procedure.
In the event of a recognisable abuse of the whistleblowing procedure, i.e. if incidents are reported which, as obviously groundless allegations, do not require serious prosecution, then legal action or disciplinary measures against the whistleblower may come into consideration.
III. Impartiality
Impartiality is safeguarded by organisational decisions. In particular, when investigating the reports, the employees of the Compliance department of ALDI Einkauf SE & Co. oHG are not bound by any technical/specialist instructions.
IV. Fair Proceedings
During the investigations, compliance is ensured with the applicable laws and company regulations in their currently valid version.
V. Presumption of Innocence
Investigations are carried out impartially and objectively with due regard for the presumption of innocence.
VI. Data Protection
The investigation of reports (including the deletion and storage of data) is carried out in
compliance with the data protection legislation (German Data Protection Regulation (DSGVO), German Federal Data Protection Act (BDSG)) and the respective internal company regulations.
E. Continuous Review of Effectiveness The effectiveness of the whistleblowing procedure will be reviewed at least once a year, as well as on an as-needed basis. If necessary, adjustments will be made to the procedure, or corrective or preventive measures will be applied.