Compliance / Rules of Procedure for the Complaints Procedure pursuant to Section 8 II of the Supply Chain Due Diligence Act (LkSG)

As a company with international ties in the supply sector, the Nolte Group sees itself as having a special responsibility to work towards improving the global human rights situation along its own supply chains and to shape its business relationships in a socially and environmentally conscious manner.

Respecting, protecting and promoting human rights and the environment within its own business area as well as along the entire value chain is the declared goal of the management of the Nolte Group. Violations of internationally recognized human rights and national and international regulations for the protection of the environment will not be tolerated.

The Nolte Group encourages persons who discover actual or potential violations of human or environmental rights – either in the supply chains or in the own business area of the Nolte Group companies – to report them via the complaint management system described below. This is because the Nolte Group pursues the goal of enabling whistleblowers to contact them easily and securely, so that human rights and environmental risks and violations in the supply chain can be identified at an early stage and violations that have occurred can be reduced and remedied.

These Rules of Procedure explain the process of submitting and processing incoming reports (also known as complaints or notifications). It describes how the complaints procedure can be achieved, who is responsible for the complaints procedure, what the concrete procedure looks like after receipt of a complaint and what measures are taken to protect the whistleblowers.

I. Scope

In principle, this complaints management system can be used to report all indications of human rights and environmental risks as well as violations of human rights or environmental obligations within the meaning of § 2 LkSG, which could have arisen as a result of the economic activities of a company of the Nolte Group or a supplier. Examples include: Human Rights Violations:

  • Employment of children under the legal age
  • Worst forms of child labour for children under the age of 18 (slavery, prostitution, etc.)
  • Forced labor, slavery, and slave-like practices
  • Failure to comply with occupational health and safety obligations under the applicable national law
  • Disregard for freedom of association
  • Unjustified discrimination in employment and unequal treatment
  • Deprivation of a fair wage (at least the minimum wage set by applicable law)
  • Unlawful eviction or unlawful deprivation of land and waters
  • Inducement of harmful soil changes, water pollution, air pollution, harmful noise emissions and excessive water consumption, insofar as they interfere with human rights positions
  • Environmental Pollution/Damage with an Impact on Human Rights

Violations of environmental law:
  • Use of persistent organic pollutants
  • Environmentally sound storage, handling, import and export of hazardous waste

II. Submission of reports and complaints

The Nolte Group has set up a central office for human rights and compliance.

Centrally responsible for the complaint management of the Nolte Group and thus the first point of contact for questions, comments or comments are:

Stephanie Neitzel,
Attorney-at-Law, Chief Compliance Officer, Human Rights Officer, Complaints Officer
Location Nolte Kitchens, Löhne,

Manuel Hüsener,
Team Leader Purchasing Nonwood, Complaints Officer
Location Nolte Kitchens, Löhne

The persons named are the exclusive point of contact for whistleblowers throughout the entire complaint procedure. The two persons guarantee that they will act impartially. In the context of their function as complaints officers, they act independently and are not bound by instructions.

Whistleblowers, who can remain completely anonymous if they wish, generally have various reporting channels at their disposal. Even if whistleblowers disclose their identity, the confidentiality and protection of their personal data is guaranteed.

The Nolte Group has created the "Reporting to the LkSG" section for whistleblowers in order to give whistleblowers an opportunity to contact them, including via a contact form. A link to this section is available on the website of the respective company of the Nolte Group.

Reports sent by email to the following email addresses will reach the contact persons mentioned above: oder

Alternatively, reports can also be submitted via the following communication channels:
by post to:
Nolte Küchen GmbH & Co. KG, Anni-Nolte-Straße 4, 32584 Löhne
by phone: 05732/899-0

III. Procedure of the complaints procedure

1. Receipt of the report

Upon receipt of a complaint, the whistleblower will receive an acknowledgement of receipt by email. Confirmation of receipt is generally made within seven working days of receipt of the report. If the report is received anonymously or by (un)knowingly providing false contact details, so that it is impossible to contact the whistleblower, the Nolte Group is not obliged to identify the whistleblower in order to comply with its obligations regarding communication.

2. Examination of the report, clarification of the facts

Subsequently, the Human Rights Commissioner, together with the relevant department, examines whether the report falls within the scope of the complaints procedure.

  1. If the report does not fall within the scope of the appeal procedure, the appeal will be rejected. In the event of a rejection, the whistleblower will receive information within two weeks of receipt of the report with the reasons for the rejection, provided that a justification is permissible for legal, factual or official reasons.
  2. If the report falls within the scope of the complaints procedure, the Human Rights Commissioner will investigate the facts together with the relevant department. A statement will be made to the whistleblower within three months at the latest.
If the proceedings are continued because the report appears to be well-founded, and if it turns out during the investigation of the facts that the information provided on the facts of the case is insufficient or not relevant for further clarification of the complaint, the Nolte Group will seek further clarification in close contact with the whistleblower in order to gain a better understanding of the situation.

3. Preventive and/or remedial measures

If, on examination of the complaint, it turns out that an infringement of a Due diligence resulting from LkSG has occurred, is imminent or at least cannot be ruled out in the Nolte Group's own business area or at a direct or indirect supplier, appropriate preventive and/or remedial measures may be required, which the Nolte Group will implement and track in order to prevent or reduce violations of protected legal positions.

4. Duration of the procedure and transparency

The Nolte Group will ensure that every report received is processed carefully, transparently and in accordance with the requirements of the LkSG. The duration of the proceedings depends on the facts of the case and the associated need for clarification. It can therefore range from a few days and weeks to several months. The Nolte Group will endeavour to carry out an efficient procedure and will keep the whistleblower informed of the measures taken until the conclusion of the proceedings.

5. Cost

The procedure is free of charge for the whistleblower.

IV. Data protection and confidentiality

As part of the complaints procedure, personal data is processed in compliance with data protection regulations. § 10 (1) LkSG applies.

The Nolte Group has taken appropriate personnel, organisational and technical measures to ensure that the confidentiality and identity of the whistleblowers are maintained in the case of incoming reports and that effective protection against discrimination or punishment due to a complaint by these persons is guaranteed.

The Nolte Group does not tolerate retaliation based on complaints or reports – neither against persons employed by a company of the Nolte Group nor against persons who work for a supplier.

The persons entrusted with the complaints procedure are obliged to maintain confidentiality and to comply with data protection. Confidentiality refers to the whistleblower, the persons or persons who are the subject of the report and other persons who have become known as a result of the report.

V. Documentation of clues

Notices are kept for seven years in accordance with § 10 (1) sentence 2 LkSG.

VI. Coming into force

These Rules of Procedure shall apply from 1 January 2024.

Germersheim, December 2023

Manfred Wippermann

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