Complaints management

Complaints management

Compliance with legal regulations as well as environmental and social rules is a top priority for the NSH Group. The success of our company is based on integrity and compliance. In order to live up to this claim, it is important to learn of possible misconduct and to prevent it.

Complaints management

Compliance with legal regulations as well as environmental and social rules is a top priority for the NSH Group. The success of our company is based on integrity and compliance. In order to live up to this claim, it is important to learn about possible misconduct and to prevent it. NSH Group's whistleblower system provides the opportunity to report possible misconduct.

We investigate each report thoroughly and follow it up systematically. We also guarantee the greatest possible protection for whistleblowers, affected parties and employees who cooperate in the investigation of reported misconduct. Retaliation against whistleblowers and any employees who help promote proper conduct at NSH Group will not be tolerated. Those affected are presumed innocent until the violation is proven. Investigations will be conducted with the utmost confidentiality. The information will be processed in a fair, fast and protected procedure.


The Act on Corporate Due Diligence Supply Chains (LkSG) is aimed at identifying possible human rights and environmental violations in the supply chain. To strengthen the rights of those concerned, the Supply Chain Act obliges companies subject to its application to meet legally designated due diligence obligations to satisfy internationally recognized human rights. The complaint procedure is an elementary part of the Supply Chain Act (LkSG) whose specific implementation in the NSH group is described hereunder.

Scope & target group

The complaint procedure outlined in clauses §§ 8 and 9 is one of the core elements of the Supply Chain Act (LkSG). All persons who believe they have identified an incident relevant to a complaint should be able to report human rights- or environment-related risks, and the infringement of appropriate obligations, caused by business activities in their own area or that of an immediate supplier ( clause § 8 section 1).

Establishing an NSH complaint procedure

The NSH group makes use of a practical merging of the acceptable whistleblower hotline regulated in the German Whistleblower Protection Act  (German Abbrev.: HinSchG)  with the complaint procedure to be instituted according to the Supply Chain Act (LkSG) to create a common information channel that meets the standards legally required. An external service provider (attorney) oversees this for all locations, fulfilling any task arising in this context in a neutral way and thereby avoiding conflicts of interests.

Access to the complaint procedure

Members of the target group (hereafter: whistleblowers) may use the complaint procedure directly through any of three reporting channels at any time. These channels are accessible to the public on the homepage of the NSH group and are available as follows:



Mr Dr. Knut Karnapp
MORGENSTERN Rechtsanwaltsgesellschaft
Hohe Straße 8
09112 Chemnitz - Germany

E mail

Via phone

+49 800 – 21 000 12

Maintaining anonymity

In general, the NSH group encourages whistleblowers to disclose their identity. Anonymity will be maintained throughout the entire process, unless official requirements (such as in criminal investigation proceedings) necessarily conflict with this, or the whistleblower has given consent to disclosure in writing.

Additionally, there is in principle the option of submitting messages anonymously. However, we must note that processing may be more difficult under these circumstances, and that as a result our obligation to follow up cannot be assumed.

Complaint process

First, the whistleblowers must select the most suitable reporting channel and submit all information  required in this context to the process officer. Once this information is received, it remains at first  with the attorney, who reviews it with a notice period of seven (7) days and sends confirmation of the receipt of the information to the whistleblower.

Next, the facts of the case are communicated to the NSH location(s) concerned. To avoid potential conflicts, the facts are not sent to internal individuals, but to a committee consisting of the business management, the Compliance coordinator responsible for the location, heads of Purchasing and Human Relations, and the Human Rights Officer. All those in receipt of this information then analyze and clarify the report together, and the external officer submits the result to the whistleblower.

The process and the content of the complaint procedures are documented according to the legal regulations.

Guarantee of impartial action & confidentiality

All persons involved in the processing of the information are obliged to act impartially. They are independent and, in connection with their jobs, not bound by instructions according to these procedural rules. Beyond this commitment, they are obliged to keep all related information confidential.

Protection against discrimination

The NSH group guarantees the whistleblowers effective protection against discrimination or retaliation in accordance with clause § 8 section 4. Reprisals related to a report will not be tolerated.

Review of the complaint procedure

The effectiveness of the complaint procedure and these procedural rules shall be reviewed in accordance with clause § 8 section 5 once a year, as well as following an incident. For this purpose, to ensure continuous improvement or prevention, incoming reports will be regularly evaluated and the procedure adapted as needed.