ESRS Standard
ESRS Standard
The term"Policy" is synonymous with the term"Policy", which is used within the German version of the ESRS Standard.
23 The company shall describe the procedures it has in place to improve or cooperate in the improvement of negative impacts on Consumers and End-users with which it is associated, and the channels available to Consumers and End-users to raise concerns and have them investigated.
24. the objective of this disclosure requirement is to provide an understanding of the formal means by which Consumers and/or End-users can directly communicate their concerns and needs to the company and/or by which the company supports the availability of such channels (e.g. Grievance mechanisms) in the context of its Business relationships, and how follow-up is conducted with these Consumers and/or End-users on the issues raised and on the effectiveness of these channels.
25 The company explains the following:
(a) its general approach and procedures for taking or participating in remedial action where it has identified that it has caused or contributed to material adverse impacts on Consumers and/or End-users, including whether and how the company assesses whether the relevant remedial action is effective,
b) any specific channels through which Consumers and/or End-users can raise their concerns or needs directly with the company and have them reviewed, including whether these channels have been established by the company itself or through participation in third party mechanisms,
(c) the procedures by which the undertaking supports or requires the availability of such channels in the context of its Business relationships; and
(d) how issues raised and addressed are tracked and monitored and how the effectiveness of the channels is ensured, including through the involvement of stakeholders who are intended as target users.
26 The company shall indicate whether and how it determines that Consumers and/or End-users are aware of and trust these structures or procedures to communicate and have their concerns or needs addressed. In addition, the company shall indicate whether it has policies in place to protect individuals from retaliation if they use such structures or procedures. If such information has been provided under ESRS G1-1, the company may refer to this information.
27 If the company is unable to provide the above required information because it has not established a channel for communicating concerns and/or does not support the availability of mechanisms within its Business relationships, it shall so indicate. It may indicate a timeframe within which it intends to implement such channels or procedures.
Application Requirements (AR)
Application Requirements (AR)
AR 18 In fulfilling the requirements of the ESRS S4-3 disclosure requirement, the company may be guided by the content of the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, which focuses on remediation and Grievance mechanisms.
AR 19 Channels through which concerns or needs can be raised include Grievance mechanisms, hotlines, dialog processes or other means through which Consumers and/or End-users or their Legitimate representatives can raise concerns or needs regarding Impacts that the company is expected to address. This may include channels provided directly by the company, which must be specified in addition to other mechanisms the company may use to gain insight into the management of Impacts on Consumers and/or End-users, such as compliance audits. If the company relies solely on information about the existence of such channels provided through its Business relationships to fulfill this requirement, it may so indicate.
AR 20 To provide greater insight into the information covered by ESRS S4-3, the company may provide information on whether and how Consumers and/or End-users who may be affected have access to channels at the level of the company they are affected by in relation to any Impact materiality.
AR 21 Third party mechanisms may include those operated by government, NGOs, industry associations and other collaborative initiatives. With respect to the scope of these mechanisms, the company may indicate whether the mechanisms are accessible to all Consumers and/or End-users who may be potentially or actually affected by the company's material impacts, or to individuals or organizations acting on their behalf or who are otherwise in a position to identify adverse impacts, and whether Consumers and/or End-users (or individuals or organizations acting on their behalf or who are otherwise in a position to identify adverse impacts) can raise complaints or concerns related to the company's own activities through these mechanisms.
AR 22 With respect to the protection of individuals using the anti-retaliation mechanisms, the company may describe whether it handles grievances confidentially and upholds privacy and data protection rights; and whether it enables Consumers and/or End-users to use them anonymously (e.g., through third party representation).
AR 23 If the company indicates the extent to which it has knowledge that Consumers and/or End-users are aware of and trust these channels, the company can provide relevant and reliable data on the effectiveness of these channels from the perspective of Consumers and/or End-users. Examples of sources of information include surveys of Consumers and/or End-users who have used such channels and their satisfaction with the process and results. To illustrate the extent of use of such channels, the company may report the number of complaints received from Consumers and/or End-users during the reporting period.
AR 24 When describing the effectiveness of the channels through which Consumers and/or End-users may raise concerns, the company may be guided by the following questions based on the "Effectiveness Criteria for Non-Discriminatory Grievance Mechanisms" as set out in the United Nations Guiding Principles on Business and Human Rights. The following considerations can be applied to individual channels or to a collective system of channels:
(a) Are the channels legitimized by ensuring adequate accountability for fair conduct and building trust among stakeholders?
b) Are the channels known and accessible to Stakeholders?
c) Do the channels have known procedures, established timelines and clear procedures?
d) Do the channels ensure adequate access to sources of information, advice and expertise?
e) Do the channels provide transparency by making sufficient information available to complainants and, where appropriate, responding to an existing public interest?
f) Do the outcomes achieved through the channels comply with internationally recognized human rights?
g) Does the company draw lessons from the channels that support continuous learning both in terms of improving the channels and preventing future impacts?
h) Does the company focus on dialog with complainants as a means to find mutually agreeable solutions, rather than unilaterally determining the outcome?
Further information can be found in Principle 31 of the United Nations Guiding Principles on Business and Human Rights.
Examples from past practice
Examples from past practice
Examples serve only as an indication of how a disclosure obligation has been stated by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.
S4-3 - Processes for improving negative impacts and channels through which Consumers and End-users can raise concerns
Alternative dispute resolution
In addition to our internal complaints management system, we work with external, out-of-court dispute resolution bodies. This enables us to offer a transparent and customer-friendly solution for consumer issues.
Legal basis
Our complaints management is based on national regulations, which stipulate that transparent and appropriate procedures must be set up for handling complaints.
Development and monitoring
Last year, we recorded an 8% increase in the number of complaints processed to a total of 450 concerns.
Data protection inquiries and audits
In the reporting year, 90 inquiries regarding data subjects' rights were reported to our data protection officer and all were dealt with in a timely manner. There were no confirmed complaints from data protection authorities; two complaints are still being processed.
No reports of data protection violations pursuant to Art. 33 GDPR were required in the reporting year, as no incidents jeopardized the rights of natural persons.
Customer feedback and complaint management
The satisfaction of our customers is monitored regularly. A committee made up of members of the Executive Board and department heads reviews customer feedback and complaints on a quarterly basis. It decides on necessary actions and monitors their progress to ensure continuous improvement
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