Complaints Procedure for the German Supply Chain Act


The complaints procedure BDO Legal is intended to enable employees or external persons to report violations of human rights and environmental risks or violations at Faber-Castell or its suppliers confidentially and anonymously.  


  • Faber-Castel employees
  • Third parties (e.g. Suppliers, business partners, customers, trade unions, non-governmental organizations and other organizations that become aware of risks or violations and/or support those affected, other third parties, e.g. residents of local sites) 

What can be reported?

Violations of human rights:

  • the prohibition of child labor  
  • the prohibition of forced labor, slavery, human trafficking
  • occupational health and safety  
  • the prohibition of discrimination
  • the prohibition of withholding an adequate living wage 

Violations of environmental protection:

  • the prohibition of the manufacture of mercury-added products, the use of mercury and mercury compounds in manufacturing processes and the illegal treatment of mercury waste (Minamata Convention) 
  • the prohibition of the production and use of chemicals ("persistent organic pollutants") in accordance with the Stockholm Convention (POP Convention)  
  • the prohibition of handling, collection, storage and disposal of waste in a manner that is not environmentally sound in accordance with the Stockholm Convention (POP Convention) 

The system is currently available in German and English. However, reports can be submitted in any language.

The exact functioning of the complaints procedure is described in the Rules of Procedure.

Protection of the Whistleblower

Faber-Castell guarantees that no employee will suffer any disadvantages within the company simply by using the system. Exceptions to this are cases in which the system is misused through denunciation.   

The theoretical possibility of the system being misused - for example to damage an employee's reputation - is being considered for every report. Furthermore, is a fundamental presumption of innocence until proven otherwise.  

The system is based on a confidential treatment of all information and the identity of the whistleblower. However, it is also possible to make an anonymous report via the BDO Legal digital complaints procedure. Furthermore, all data protection regulations are complied with.  

Legal obligations to provide information to authorities and legal exceptions to the confidentiality requirement are complied with. 

Note: For complete anonymity, the report should be submitted via the Faber-Castell website outside the Faber-Castell network, for example using a personal device. 


The ombudsperson acts as an external and therefore neutral point of contact for reports (including anonymous reports) from Faber-Castell employees and external third parties. The ombudsperson ensures can be reached during normal business hours via a compliance hotline. The ombudsperson can also be contacted by e-mail and by post using the following contact details: 

Jesko Trahms 
BDO Legal Rechtsanwaltsgesellschaft mbH 
Zielstattstraße 40 
81379 München 
Phone: +49 (0) 1733091491 

External Reporting Procedure:

Alternatively, the external reporting procedures listed on the homepage of the German Federal Office of Justice can be used. 

Rules of Procedure:

Rules of Procedure for the Complaints Procedure