Rules of Procedure
for the complaints procedure pursuant to Section 8 of the German Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz; LkSG)
Our complaints procedure shall put people into the position to report if 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 business area. These Rules of Procedure describe the topics to which reports may relate, how they can be submitted and what happens after a report has been submitted.
We will be happy to answer any questions you may have about the procedure, either directly via the reporting system or via the contact details provided under "Responsibility for the complaints procedure".
I. Scope
This complaints procedure is available to all persons or groups of persons who are directly or indirectly affected by human rights or environmental risks or violations within QIAGEN’s own business area or within QIAGEN’s supply chains. In principle, all risks and violations in the field of human rights and environmental obligations can be reported via this reporting system. Specific examples:
Human Rights Violations:
• Child labour
• Forced Labor and Slavery
• Discrimination and unequal treatment
• Disregard for freedom of association
• Deprivation of a decent wage
• Working conditions that are hazardous to health
• Unlawful evictions or wrongful deprivation of land
• Unlawful use by private or public security guards
• Contamination of water, soil and air that can contribute to a violation of human rights
Violations of environmental law:
• Use of mercury (according to the Minamata Convention)
• Use of persistent organic pollutants (according to the Stockholm Convention)
• Environmentally sound storage, handling, import and export of hazardous waste (as defined by the Basel Convention)
II. Submission of complaints or reports
Complaints or reports can be submitted to our QIAintegrity Line via either of the following channels:
• In writing or orally via the digital reporting system that is available under the following link:
https://qiagen.integrityline.com/frontpage
Complaints or reports can be made in the preferred language. It is possible to submit information around the clock. If desired, whistleblowers can remain completely anonymous. Even if whistleblowers disclose their identity, their personal data will be kept confidential and protected in accordance with applicable law.
The digital reporting system allows also for anonymous whistleblowers to remain in contact with QIAGEN even after they have submitted a report. The use of the system is, of course, free of charge for the whistleblower.
III. Procedure
The processing of all incoming complaints or reports within the scope of these rules of procedure typically follows a structured process, which is described below.
1. Acknowledgement of receipt
Upon receipt of the report, whistleblowers will receive an acknowledgment of receipt, usually within seven days of receipt of the report.
2. Verification
It will then be verified, whether the report falls within the scope of the complaints procedure pursuant to these rules of procedure.
3. Keeping contact
We will keep in contact with the whistleblower.
4. Assessment
We will verify the validity of the report and make a risk-based assessment of the quality of the reportet misconduct or risk;
5. Alignment
Where necessary and possible, we will ask the whistleblower for further information. We will discuss the facts of the case with the whistleblower.
6. Follow up
We will diligently follow up on the report. Follow up can comprise any action taken to assess the accuracy of the allegations made in the report and, where relevant, to address the breach or risk reported.
7. Feedback
We will provide feedback to the whistleblower within a reasonable time frame, not exceeding three months, in particular on the action envisaged or taken as follow up and the grounds for such follow up.
The duration of the procedure depends on the facts of the case and can range from a few days and weeks to a few months. As a matter of principle, we strive to bring the procedure to a satisfactory solution as efficiently as possible. In addition, we always make every effort to keep the whistleblower informed of the measures taken and the further course of events. To this end, we recommend that whistleblowers who use the digital reporting system log in regularly and check their own case for new messages.
IV. Responsibility for the complaints procedure
Centrally responsible for our complaints procedure and primary contact person(s) for questions or comments:
QIAGEN GmbH
Head of Global Legal Affairs and Compliance
Qiagen Strasse 1
40724 Hilden
Germany
Email: Compliance@qiagen.com
We also recommend that whistleblowers use the possibility of communication via our digital reporting system to address questions or comments directly to the responsible person.
V. Protection against discrimination or punishment
We work to ensure that persons who report in good faith do not have to experience discrimination or punishment as a result of their reporting.
To this end we will maintain the confidentiality of the identity of reporting persons, the persons being subject of the report and any other persons mentioned in the report in accordance with applicable law.
If the reporting person is employed by QIAGEN, we will neither retaliate nor attempt or threaten to retaliate against such person for having made a report. Any act of retaliation contrary to the above will have serious consequences which can include disciplinary action up to and including discharge.
If, for example, the reporting person is employed by a supplier, we work with the supplier to ensure that the person enjoys a comparable level of protection. To ensure that the reporting person is not subjected to discrimination, punishment or similar retaliation, we will endeavor to maintain contact with the reporting person beyond the conclusion of the proceedings.
However, these protective measures do not apply if a reporting person knowingly or gross-negligently reports inaccurate information.
VI. Effectiveness review
We review the effectiveness of this complaints procedure at least once a year and on an ad hoc basis and adjust it as necessary.
VII. Entry into force
These rules of procedure enter into force on 1 January 2024 and remain effective until terminated or replaced.