Purpose

As part of the requirements of the German Supply Chain Due Diligence Act (LkSG) (effective from 1st January 2024), we are required to have a complaints procedure in place, which is made publicly available, detailing what steps the business will take in the event of receiving any grievances from within or externally-from the company with regards to N26’s supply chain and potential human rights and environmental-related violations. This documentation will detail what our procedure is, including the relevant roles and responsibilities. This policy is also in line with ISO 37301 (8.3 & 8.4) standards.

Complaints Procedure

Any persons, either internally at N26 or from a supplier N26 is contracting, can freely find the contact details for submitting a complaint about a possible violation to the German Supply Chain Due Diligence Act (LkSG) online through the N26 Supplier Portal. The contact details for submitting this notification can be found here: n26.com/de/suppliers.

1. The persons, who may remain anonymous throughout the process, submits an email to suppliers@n26.com detailing their perceived violation of the German Supply Chain Due Diligence Act (LkSG).
2. This email is received by Sustainable Sourcing and the Human Rights Officer (HRO), who are then responsible for responding to the persons to confirm receipt and provide assurance that the case will be investigated.
3. Sustainable Sourcing is then responsible for investigating the possible violation, together with the Contract Manager and Business Owner of the supplier, where required.
4. Any direct contact with the supplier in question is to happen between the Contract Manager and Business Owner, with Sustainable Sourcing and the HRO in copy for visibility.
5. It is the responsibility of Sustainable Sourcing/HRO to ensure that any remedial/preventative measures that are implemented are in line with the severity of the violation, and the potential risks (environmental, human rights-related, or otherwise) that may arise from the violation itself and its potential recurrence.
6. The persons must be informed of the outcome of the investigation, and any measures that come as a result of the investigation.
7. The violation must be reported in the annual LkSG report to BaFa, Federal Office for Economic Affairs and Export Control / Bundesamt für Wirtschaft und Ausfuhrkontrolle, compiled by Sustainable Sourcing/HRO.
8. This procedure is to be reassessed on an annual basis to ensure effectiveness.