German Supply Chain Due Diligence Law (LkSG) Rules of procedure

Rules of Procedure (Section 8 (2) LkSG) for PSI Software SE

Status:

What is the purpose of these rules of procedure?
On 01.01.2023, the German Act on Corporate Due Diligence to Prevent Human Rights Violations in Supply Chains (Lieferkettensorgfaltspflichtengesetz - LkSG) came into force in Germany. The aim of the law is to improve the protection of human rights and the environment in companies' own business areas and along the corporate supply chain. To this end, the law has also established a series of due diligence obligations for us. Among other things, the LkSG requires companies to have an appropriate Grievance Procedure in place through which both internal (i.e. employees) and external persons (such as suppliers) can contact us to report human rights and environmental risks or violations.
What is the function of the Grievance Procedure?
The Grievance Procedure should fulfil two functions:
a) Firstly, the complaints procedure should serve as an early warning system and enable us to identify problems in the supply chain at an early stage and ideally to resolve them promptly, especially before people and/or the environment are actually harmed.
b) On the other hand, we can be made aware of imminent or existing violations of legal interests via the Grievance Procedure. The company can then take effective remedial action.
To which PSI locations do these Rules of Procedure apply?
These Rules of Procedure apply directly to PSI Software SE and all its (German) locations.
What can be reported?
The Grievance Procedure can and should be used to draw PSI's attention to human rights or environmental risks or violations in our own business area and in our supply chain. The term “supply chain” is broad and includes both direct suppliers of PSI, with whom PSI has a contractual relationship, and indirect suppliers, i.e. the “suppliers' suppliers”.
The most relevant human rights and environmental risks are in particular:
- All forms of slavery, economic exploitation and forced or child labour;
- Endangerment or violation of occupational health and safety regulations, for example due to inadequate safety standards, lack of protective measures or insufficient training and instruction;
- Unjustified unequal treatment in the employment relationship, for example due to national or ethnic origin or gender;
- Violation of minimum wage regulations;
- Improper storage or disposal of hazardous waste.
The above list is for clarification purposes only and is of course not exhaustive.

NOTICE:
If you want to point out risks or violations, it is better in case of doubt to submit the notice and leave the assessment of whether the notice falls within the scope of the law to the responsible team at PSI.
Who can submit a complaint?
Firstly, all employees in their own area of business can make use of this Grievance Procedure. In addition, it is also open to external persons, e.g. our direct and indirect suppliers and the employees working for them. People who are not directly affected by risks are also expressly free to use the Grievance Procedure. Use of the Grievance Procedure is free of charge.
To whom / where can I address my complaint?
PSI has appointed a Complaints Officer who works together with a Complaints Team. The Complaints Team consists of people from the relevant departments. The Complaints Officer is therefore also the first point of contact for receiving and investigating your reports or complaints. The Complaints Officer and the Complaints Team can be contacted as follows:
Natalia Hartenstein
Legal Counsel
Complaints Officer LkSG

PSI Software SE
Dircksenstraße 42-44
10178 Berlin / Germany
complains.supply.chain@psi.de
Am I protected against discrimination if I make such a complaint?
Of course this is the case. This is an important concern for PSI. We will not tolerate discrimination in any form whatsoever; if necessary, PSI will take legal action against the person(s) who discriminates against you because of the information provided.
The Complaints Officer and the members of the Complaints Team will be trained accordingly and will investigate your complaint impartially and independently. The Complaints Officer and the members of the Complaints Team are not bound by instructions and are obliged to maintain confidentiality. All this guarantees a professional handling of your complaint, which minimizes the risk of your identity being inadvertently disclosed to unauthorized persons and thus also the risk of discrimination.
You are also welcome to contact the Complaints Officer and the Complaints Team after the procedure has been completed to ensure that you are not disadvantaged in the follow-up.
What happens after I have submitted a complaint?
After submitting a complaint, you will first receive an acknowledgement of receipt. Immediately aftewards, we will check whether the subject of your complaint falls within the scope of the complaints procedure. If it does not, you will then be informed of this, including a brief explanation.
If your complaint falls within the scope of application, you will be informed promptly about the next steps and the likely timeline for the procedure. The Complaints Officer and, if applicable, the Complaints Team will also discuss the facts of the case with you and, if necessary, ask further questions in order to better understand your complaint.
They will also discuss your expectations with regard to possible preventative or remedial measures. If necessary, the Complaints Officer will offer the option of an amicable dispute resolution procedure. This involves an attempt to find an amicable solution with the help of a neutral and mediating third party. If the optional dispute resolution procedure cannot be considered or fails and your complaint proves to be well-founded, a proposal for a remedy will be developed together with you. In the event of a well-founded complaint, the agreed remedial measure will then be implemented and followed up. The result will be evaluated with you and the procedure will then be terminated. In the event of an unfounded complaint, you will receive a corresponding explanation
Final provisions
a) Review of the effectiveness of the complaints procedure
The effectiveness of the Grievance Procedure is reviewed at least once a year and, if necessary, on an ad hoc basis. The findings and identified potential for improvement from the information received to date and the respective procedures as well as from the risk analyses are taken into account.
b) Languages
These rules of procedure will initially be published in German and English. Other languages will follow after the risk analysis has identified further relevant target groups.
c) Entry into force / Publication
These Rules of Procedure enter into force on 01.11.2024 and will be published. It replaces the Rules of Procedure of 01.01.2024.

Berlin, 23.10.2024

PSI Software SE

Rules of Procedure (Section 8 (2) LkSG) for PSI Transcom GmbH

What is the purpose of these rules of procedure?
On 01.01.2023, the German Act on Corporate Due Diligence to Prevent Human Rights Violations in Supply Chains (Lieferkettensorgfaltspflichtengesetz - LkSG) came into force in Germany. The aim of the law is to improve the protection of human rights and the environment in companies' own business areas and along the corporate supply chain. To this end, the law has also established a series of due diligence obligations for us. Among other things, the LkSG requires companies to have an appropriate Grievance Procedure in place through which both internal (i.e. employees) and external persons (such as suppliers) can contact us to report human rights and environmental risks or violations.
What is the function of the Grievance Procedure?
The Grievance Procedure should fulfil two functions:
a) Firstly, the complaints procedure should serve as an early warning system and enable us to identify problems in the supply chain at an early stage and ideally to resolve them promptly, especially before people and/or the environment are actually harmed.
b) On the other hand, we can be made aware of imminent or existing violations of legal interests via the Grievance Procedure. The company can then take effective remedial action.
To which PSI locations do these Rules of Procedure apply?
These Rules of Procedure apply directly to PSI Transcom GmbH and all its (German) locations.
What can be reported?
The Grievance Procedure can and should be used to draw PSI's attention to human rights or environmental risks or violations in our own business area and in our supply chain. The term “supply chain” is broad and includes both direct suppliers of PSI, with whom PSI has a contractual relationship, and indirect suppliers, i.e. the “suppliers' suppliers”.
The most relevant human rights and environmental risks are in particular:
- All forms of slavery, economic exploitation and forced or child labour;
- Endangerment or violation of occupational health and safety regulations, for example due to inadequate safety standards, lack of protective measures or insufficient training and instruction;
- Unjustified unequal treatment in the employment relationship, for example due to national or ethnic origin or gender;
- Violation of minimum wage regulations;
- Improper storage or disposal of hazardous waste.
The above list is for clarification purposes only and is of course not exhaustive.

NOTICE:
If you want to point out risks or violations, it is better in case of doubt to submit the notice and leave the assessment of whether the notice falls within the scope of the law to the responsible team at PSI.
Who can submit a complaint?
Firstly, all employees in their own area of business can make use of this Grievance Procedure. In addition, it is also open to external persons, e.g. our direct and indirect suppliers and the employees working for them. People who are not directly affected by risks are also expressly free to use the Grievance Procedure. Use of the Grievance Procedure is free of charge.
To whom / where can I address my complaint?
PSI has appointed a Complaints Officer who works together with a Complaints Team. The Complaints Team consists of people from the relevant departments. The Complaints Officer is therefore also the first point of contact for receiving and investigating your reports or complaints. The Complaints Officer and the Complaints Team can be contacted as follows:
Natalia Hartenstein
Legal Counsel
Complaints Officer LkSG

PSI Software SE
Dircksenstraße 42-44
10178 Berlin / Germany
complains.supply.chain@psi.de
Am I protected against discrimination if I make such a complaint?
Of course this is the case. This is an important concern for PSI. We will not tolerate discrimination in any form whatsoever; if necessary, PSI will take legal action against the person(s) who discriminates against you because of the information provided.
The Complaints Officer and the members of the Complaints Team will be trained accordingly and will investigate your complaint impartially and independently. The Complaints Officer and the members of the Complaints Team are not bound by instructions and are obliged to maintain confidentiality. All this guarantees a professional handling of your complaint, which minimizes the risk of your identity being inadvertently disclosed to unauthorized persons and thus also the risk of discrimination.
You are also welcome to contact the Complaints Officer and the Complaints Team after the procedure has been completed to ensure that you are not disadvantaged in the follow-up.
What happens after I have submitted a complaint?
After submitting a complaint, you will first receive an acknowledgement of receipt. Immediately aftewards, we will check whether the subject of your complaint falls within the scope of the complaints procedure. If it does not, you will then be informed of this, including a brief explanation.
If your complaint falls within the scope of application, you will be informed promptly about the next steps and the likely timeline for the procedure. The Complaints Officer and, if applicable, the Complaints Team will also discuss the facts of the case with you and, if necessary, ask further questions in order to better understand your complaint.
They will also discuss your expectations with regard to possible preventative or remedial measures. If necessary, the Complaints Officer will offer the option of an amicable dispute resolution procedure. This involves an attempt to find an amicable solution with the help of a neutral and mediating third party. If the optional dispute resolution procedure cannot be considered or fails and your complaint proves to be well-founded, a proposal for a remedy will be developed together with you. In the event of a well-founded complaint, the agreed remedial measure will then be implemented and followed up. The result will be evaluated with you and the procedure will then be terminated. In the event of an unfounded complaint, you will receive a corresponding explanation.
Final provisions
a) Review of the effectiveness of the complaints procedure
The effectiveness of the Grievance Procedure is reviewed at least once a year and, if necessary, on an ad hoc basis. The findings and identified potential for improvement from the information received to date and the respective procedures as well as from the risk analyses are taken into account.
b) Languages
These rules of procedure will initially be published in German and English. Other languages will follow after the risk analysis has identified further relevant target groups.
c) Entry into force / Publication
These Rules of Procedure enter into force on 01.11.2024 and will be published. It replaces the Rules of Procedure of 01.01.2024.

Berlin, den 23.10.2024
PSI Transcom GmbH