United Internet has implemented effective complaints procedures. These complaints procedures perform two key functions. Firstly, they serve as an early warning system, enabling e.g., human rights risks to be identified at an early stage, while secondly they provide access to appropriate remedies . Where reports of or complaints relating to potential or actual breaches of duty are received and subsequently confirmed, remedial action is taken to end or at least minimize these grievances.
Access to the confidential contact points (the whistleblower system, compliance managers, and United Internet Vertrauenspersonen) is easy and employees are encouraged to broach their concerns early on. This is ensured using binding guidelines and policies such as the Whistleblower Protection Policy and by providing comprehensive information.
One core component of the complaints procedure is in-person dialog with affected employees. This inclusive integration process enables the Company to develop remedial actions reflecting the needs and expectations of those affected. United Internet attempts to resolve conflicts through mediation and negotiation, so as to arrive at sustainable and mutually acceptable solutions. Compliance managers and the United Internet Vertrauenspersonen offer employees a way of expressing their issues or concerns in person and in a confidential dialog outside of their direct working environment. United Internet’s Vertrauenspersonen offer particular support in the case of professional and personal challenges. In addition, managers can be approached and treat workers’ concerns sensitively and in a solutions-driven manner.
The electronic whistleblower system is available 24 x 7 in a variety of languages both internally via the intranet and externally via the corporate websites, and can be used by employees at all segments. The effectiveness of the complaints procedure is assessed both at regular intervals and ad hoc. When reviewing its effectiveness, United Internet follows the effectiveness criteria set out in the UN Guiding Principles on Business and Human Rights. Measures include e.g., surveying affected employees with regard to the remedial actions implemented, regular feedback sessions, and monitoring by the Human Rights Officer. The results of these measures are included in the adaptations made to the due diligence process.
All these measures serve to create trust. Finally, removing barriers to access also enhances workforce trust in the process’s credibility. In addition, “sounding board” meetings serve as platforms for feedback and discussion, fostering constructive feedback on corporate processes. These are attended, for example, by selected departmental employees who represent the concerns of their colleagues in the department. Management answers these concerns directly and they are also taken on board by HR.
In fiscal year 2024, 32 reports of potential compliance violations were sent to the Compliance organization via the channels already mentioned, and were checked by it. Of these, five related to discrimination (including harassment), while eight others related to other social factors or matters within the Company’s own workforce. An actual violation was found to exist in two of the five potential incidents of discrimination, leading to remedial actions being taken. No reports of potential human rights incidents were submitted. No fines, penalties or compensation payments resulted from the abovementioned incidents and complaints. The confirmed cases resulted in remedial actions being taken. The Management Board and the Supervisory Board’s Audit and Risk Committee are informed ion a quarterly basis of reports of possible compliance violations. These clear reporting channels help actively promote a culture of trust, while insights from processing the reports are included in the modification of the due diligence processes.
As part of its complaints management activities, United Internet has implemented a process that is modeled on the steps set out in the DIN ISO 37002 Whistleblowing Management standard, and has established a robust procedure for capturing, documenting, and monitoring employee concerns.
For United Internet, a complaints procedure is only effective if employees are aware of it, if it is considered to be trustworthy, and if it enables reports and complaints to be submitted – before a breach of duty occurs. The Company aims to achieve such effectiveness using a number of measures:
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