Rules of Procedure

​Section 8 of the German Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz; LkSG)

Our grievance procedure empowers individuals to report actual or potential issues concerning human rights or environmental concerns within both our supply chains and our direct operations.These guidelines outline the subjects eligible for reporting, the methods available for submission, and the subsequent steps following a report.

For any inquiries regarding this procedure, please contact us directly through the reporting system or via the contact information provided under “Responsibility for the complaints procedure.

I. Scope

Probgen Biotech India Private Limited’s grievance mechanism is available to all individuals or groups directly or indirectly affected by human rights or environmental risks or violations within our operations or supply chains.This system allows reporting of various issues, including

  • Forced Labor and Slavery: Situations where individuals are coerced into work under threat or deceit, often facing poor conditions and abuse. Thomson Reuters: Clarifying the com

  •  Treatment: Unjust treatment based on race, gender, religion, or other protected characteristics.

  • Violation of Freedom of Association: Suppression of workers’ rights to form or join unions and engage in collective bargaining.

  • Denial of Fair Wages: Failure to provide legally mandated wages, including overtime and benefits.

  • Hazardous Working Conditions: Unsafe workplaces that expose employees to health risks or physical harm.

  • Unlawful Evictions or Land Dispossession: Forced removal of individuals from their homes or land without legal justification or compensation.

  • Misuse of Security Forces: Improper use of security personnel, including violence or intimidation against workers or communities.

  • Environmental Harm Impacting Human Rights: Pollution or environmental degradation that adversely affects communities’ health and livelihoods.

By utilizing this grievance mechanism, stakeholders can confidentially report concerns, which will be addressed promptly to uphold our commitment to human rights and environmental standards.

II. Submission of complaints or reports

Probgen Biotech India Private Limited’s reporting system is designed to accommodate reports in the preferred language of the whistleblower, ensuring accessibility and ease of use. The system operates 24/7, allowing individuals to submit information at any time. Whistleblowers have the option to remain completely anonymous; however, if they choose to disclose their identity, their personal data will be kept confidential and protected in accordance with applicable laws.

The digital reporting platform also facilitates ongoing, anonymous communication between the whistleblower and Probgen, even after the initial report is submitted. Utilizing this system is free of charge for all whistleblowers.

This approach aligns with best practices for anonymous reporting systems, which emphasize ease of use, confidentiality, and the ability to maintain communication throughout the reporting process.

III. Procedure

Probgen Biotech India Private Limited has established a structured process for handling all incoming complaints or reports under this grievance procedure, which typically includes the following steps:

  1. Acknowledgment of Receipt: Upon receiving a report, Probgen will acknowledge its receipt, generally within seven days.

  2. Verification: The report will be assessed to determine its relevance to the grievance procedure.

  3. Maintaining Contact: Probgen will maintain communication with the whistleblower throughout the process.

  4. Assessment: The validity of the report will be evaluated, and a risk-based assessment of the alleged misconduct or risk will be conducted.

  5. Information Gathering: If necessary, Probgen will request additional information from the whistleblower and discuss the case details.

  6. Follow-up: Probgen will diligently pursue actions to verify the allegations and, where applicable, address the reported breach or risk.

  7. Feedback: Probgen will provide feedback to the whistleblower within a reasonable timeframe, not exceeding three months, regarding the actions taken and the rationale behind them.

The duration of this procedure varies depending on the case’s complexity, ranging from a few days to several months. Probgen strives to resolve each case efficiently and will keep the whistleblower informed of progress. Whistleblowers are encouraged to regularly check the digital reporting system for updates on their cases.

IV. Protection against discrimination or punishment

Probgen is committed to ensuring that individuals who report concerns in good faith do not face discrimination or retaliation due to their actions.

We will keep the identity of the reporter, as well as those mentioned in the report, confidential in accordance with applicable laws.

If the reporter is an employee of Probgen, no retaliation, threats of retaliation, or any adverse actions will be taken against them for submitting a report. Any retaliatory actions will be taken seriously and may result in disciplinary measures, including termination.

If the reporter is employed by a supplier, we work with the supplier to ensure that the individual is equally protected. We will take steps to maintain communication with the reporter to ensure they are not subjected to retaliation or discrimination, even after the conclusion of the process.

These protective measures do not apply if the reporter knowingly or recklessly submits false information.

V. Protection against discrimination or punishmen

Probgen Biotech India Private Limited evaluates the effectiveness of its complaints procedure at least annually and as needed, making adjustments when appropriate.

VI. Entry into force

These rules of procedure become effective on January 1, 2024, and will continue in effect until they are terminated or replaced.