Malpractice at Lenzing concerns all of us!

Why should I submit a report?

We expect all employees to comply with our Code of Conduct and all applicable legal and company-internal regulations, guidelines and procedural instructions ( “REGULATIONS”). This ensures our efficiency and protects our long-term success within the scope of a compliance culture.

You may have compliance-related concerns or knowledge about actual or potential violations of our REGULATIONS that pose a threat to the company. Your report will help us to protect LENZING from a wide range of dangers and risks and secure our efficiency and long-term success within the scope of a compliance culture together.

What sort of compliance-related reports will help your organisation?

Compliance-related concerns and information about any violation of our REGULATIONS should be described in as much detail as possible. Reports could include the following information, for example: Background of and reasons for the event, persons involved, time and place of the event, evidence (documents, etc.).

You will receive detailed information on the possible categories of a report during the reporting process.

What is the process for submitting a report? How do I set up a postbox?

To submit an anonymous or personalised report, start by clicking the “Submit report” button located on the top left side of our introduction page.

The reporting process consists of four steps:

1. First, you will be asked to read some information on the protection of your anonymity and to respond to a security query.
2. On the following page, you will be asked about the category of your report.
3. On the submission page, you can elaborate on your report in your own words and answer questions about the incident by simply selecting responses. You can type up to 5,000 characters into the free text field. This corresponds to a full A4 page. You may also submit a file of up to 5 MB to support your report. Please bear in mind that documents can contain information about the author. Following the submission of your report, you will receive a reference number to confirm that you have sent this report.
4. Please subsequently set up your own secured postbox. You will receive feedback from us via this postbox, including answers to questions and information about the progress of your report.

If you already have a secured postbox, you can access it directly via the “Login” button. First, you will have to answer a security query.

As long as you do not enter any data from which conclusions about your person can be drawn, the BKMS^® System will protect your anonymity technically.

Please rest assured that we are interested only in the case you are reporting. Malpractices should be revealed and financial losses prevented.

How do I receive feedback and remain anonymous at the same time?

The overriding principle of the BKMS^® procedure in use is the protection of the whistleblower. The system's anonymity protection function is certified by an independent body.

When setting up your secured postbox, please select your own pseudonym/ user name and password. Your report is kept anonymous through encryption and other specialised security measures. You will never be asked for personal information at any time during the reporting process. Do not submit any information that can be traced back to you. Please do not use a computer provided by your employer to submit your report.

Via the secured postbox, an examiner will give you feedback about the further processing of your information, or ask you questions if some details are still unclear - you remain anonymous throughout the dialogue. We are interested in reports to avoid damage, not in you as a whistleblower.

Rules of Procedure for the Complaints Procedure under the LkSG

according to § 8 (para. 2) of the German Supply Chain Due Diligence Act (in German Lieferkettensorgfaltspflichtengesetz (LkSG))

Our complaints procedure is intended to enable people to report when they identify actual or potential problems in the area of human or environmental rights. These can be problems in our supply chains, but also in our own area of business. These rules of procedure describe which issues can be reported, how they can be submitted and what happens after a report has been made.

Scope

In principle, all issues in the area of human rights and environmental rights violations can be reported via this reporting system. Specific examples are:

Human rights violations:

• Child labour
• Forced labour and slavery
• Discrimination and unequal treatment
• Disregard for freedom of association
• Withholding of a decent wage
• Working conditions that are hazardous to health
• Unlawful eviction or deprivation of land
• Unlawful use of private or public security forces
• Pollution of water, soil and air that may contribute to human rights violations

Environmental rights violations:

• Use of mercury (under the Minamata Convention).
• Use of persistent organic pollutants (under Stockholm Convention)
• Failure to store, handle, import or export hazardous waste in an environmentally sound manner (under Basel Convention)

Submitting notifications and complaints

We recommend submitting information via our digital reporting system:

https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=12len14&c=-1&language=ger

Reports can be submitted in your preferred language. The submission of reports is possible 24/7. If desired, whistleblowers can remain completely anonymous. Even if whistleblowers disclose their identity, confidentiality and the protection of personal data are guaranteed in any case.
Through the system, reporting persons - even if they remain anonymous - can stay in contact with an external lawyer even after submitting a report. The use of the system is, of course, free of charge for the person providing the information.

Procedure

The processing of all incoming reports follows a structured process, which is described below.

1. Receipt of the report

Upon receipt of the report, whistleblowers receive a confirmation of receipt, usually within seven days of receipt of the report. Of course, this assumes that the whistleblower has set up an (anonymous) mailbox. Unfortunately, people who have not set up a mailbox cannot be contacted.

2. Review of the report

The content of the report is subsequently checked. In this phase, questions may arise which are clarified in dialogue with the whistleblower. Depending on the content, the further procedure is determined. If the complaint is rejected, the whistleblower receives a statement of reasons.

3. Clarification of the facts

If the procedure continues, the issue is discussed and examined with the whistleblower. Optionally, a procedure for consensual dispute resolution may be suggested.

4. Remediation

Remediation measures may be necessary to resolve reported problems. If remediation measures have been agreed, they will be implemented and followed up.

5. Review and closure

The whistleblower will be informed about the result of the investigation (if a postbox was set up).

The duration of the procedure strongly depends on the respective facts and can range from a few days and weeks to several months. In principle, we strive to lead the proceedings to a satisfactory solution as efficiently as possible. In addition, we always try to keep the whistleblower informed about the measures taken and the further course of the case. For this purpose, we recommend that whistleblowers who use the digital reporting system log in regularly and check their own case for new messages.

Settlement of disputes by mutual agreement

In the case of some complaints, it may be advisable to involve a neutral and mediating third party. In this way, we would like to contribute to finding a satisfactory solution that can be supported by all parties. If it becomes apparent during the procedure that an agreement-based settlement of the dispute could be useful, we will endeavor to involve such a neutral party.

Responsibility for the complaints procedure

Centrally responsible for our complaints procedure and primary contact person(s) for questions or comments:

Lenzing Group Compliance Officer:
Florian Wirth
E-Mail: f.wirth@lenzing.com

We also recommend that whistleblowers use the option of communicating via our digital reporting system to address questions or comments directly to the responsible processor.

Protection from disadvantage or punishment

We make an effort to ensure that whistleblowers do not suffer discrimination or punishment as a result of their report. We will not tolerate retaliation for making a complaint or providing information. If the whistleblower is employed by our company, this includes protection against termination, demotion, suspension, threats, harassment, or other discrimination with respect to the terms or conditions of employment of a person.
For example, if the reporting person is employed by a supplier, we will strive together with the supplier to ensure that the person has a comparable level of protection. In order to ensure that the whistleblower is not subject to discrimination, punishment or similar retaliation, we will seek to maintain contact with the whistleblower beyond the conclusion of the case.

Lenzing, 01.01.2024