Complaints Procedere

General information

Conflict resolution and the investigation of complaints are essential for the REDcert GmbH to ensure the reliability and integrity of the REDcert-EU scheme.

Protecting the REDcert-EU scheme from abuse is important to ensure that those who have invested time and resources in complying with the requirements of the REDcert-EU scheme are safely identified and their interests are protected. REDcert is interested in resolving conflicts through dialogue with the parties concerned before formal proceedings are initiated.

What can be accepted as complaint(s)?

A “complaint” is a statement by an interested party that expresses dissatisfaction and is linked to a claim against the activities of the scheme operator.

Complaints of any kind may be an indication of suspected violations or weaknesses in scheme participants, certification bodies and the voluntary scheme itself, and may trigger additional inspections. The scheme operator has set up a complaint management system for this purpose.

A prerequisite for the investigation of a complaint is objective evidence and as comprehensive and concrete information as possible. A complaint based solely on hearsay or rumor is not sufficient for further investigation by REDcert.

Complaints are inadmissible, if

the requirements as to form and content are not met. This includes complaints and appeals that are not adequately supported by objective and sufficient evidence necessary to gain a clear understanding of the situation at hand.
the complaint seeks adjustments to the recognized REDcert-EU scheme.
the complaint seeks to modify sanctions imposed by REDcert for violations or infractions of REDcert requirements.
the reason for the complaint does not explicitly relate to REDcert GmbH or to activities carried out under REDcert.

How to submit a complaint to REDcert?

The complaint must be sent in writing, including all verifiable information, to the office of REDcert GmbH, clearly marked as a complain via post or e-mail (This email address is being protected from spambots. You need JavaScript enabled to view it.). Further current contact data can be found on the REDcert website https://www.redcert.org/en/contact.html. The prerequisite for investigating a complaint is objective evidence and information that is as comprehensive and concrete as possible.

Anonymous indications or comments can also submitted with the following form:

Postal Address:

REDcert GmbH
Schwertberger Str. 16
53177 Bonn
Germany
Phone: 0049 228 35 06 200

Complaint procedere (summary) and timeline

Every complaint that meets the requirements in terms of form and content is accepted, analyzed and tracked as shown in Figure 1.

The individual steps in the complaint process are carefully documented by the scheme operator.

The complaint process ensures the confidentiality and protection of persons who report infringements or log complaints. In accordance with Directive (EU) 2019/1937 the identity of the reporting person is not disclosed to anyone beyond the authorized staff members competent to receive or follow up on reports, without the explicit consent of that person. This shall also apply to any other information from which the identity of the reporting person may be directly or indirectly deduced (Chapter 5, Article 16 (1)). By way of derogation from paragraph 1, the identity of the reporting person and any other information referred to in paragraph 1 may be disclosed only where this is a necessary and proportionate obligation imposed by Union or national law in the context of investigations by national authorities or judicial proceedings, including with a view to safeguarding the rights of defense of the person concerned.

The person (reporting person) who initiates the complaint as well as any other parties involved (e.g. competent authorities or the European Commission) are informed of the results of the complaint investigations.

Complaint procedere in the REDcert-EU scheme (Fig 1):

Compliant Procedere

The workflow shown in the figure above looks as follows in detail:

① All communication channels are available to reporting person to submit the complaint to the scheme operator: e-mail, fax, letter by post. Most importantly, we would like to once again stress the possibility of contacting us anonymously via the REDcert website.

② The scheme operator decides whether the report meets the definition of a complaint and verifiable information is available. If so, the scheme operator documents the receipt of the complaint and generates a progress report in which all other measures and incidents related to the complaint are entered chronologically and linked to the relevant information and accompanying documents.

As part of an initial analysis of the complaint, the following is systematically determined and documented:

_{the reporting person (incl. contact data (if known and taking into account the Directive (EU) 2019/1937)}
_{the reason for the complaint (information on the companies involved, types and quantities of biomass or biofuels/bioliquids/biomass fuels, time periods and other details)}
_{possible causes of the complaint (as long as this can be determined with certainty at that time)}
_{potential magnitude of the complaint with respect to the integrity of the REDcert scheme}
possible conflicts of interest

③ The complaint is understandable and admissible according to the REDcert guidelines for complaints.

④ If the complaint is not sufficiently clear, the reporting person who initiated the compliant is contacted and an attempt is made to obtain the missing information from the perspective of the reporting person.

⑤ REDcert keeps a register of complaints received and measures taken, which ensures a transparent process to reduce conflicts of interest and the possibility of monitoring.

⑥ If the complaint is sufficiently substantive and convincing, the reporting person will receive a letter/e-mail within five working days confirming receipt of the complaint and assuring him that the complaint will be further investigated and that information on its progress will be provided.

⑦ REDcert is required to provide a summary of the registered complaints to the Commission through the annual reporting process for reasons of transparency.

⑧ Possible conflicts of interest are investigated.

⑨ If internal conflicts of interest are identified, they are resolved by a decision of the management (e.g. if the complaint is directed against an employee of REDcert, the employee is exempted from handling the complaint by the management).

⑩ The scheme operator determines measures to permanently eliminate the reason for the complaint and its causes.

⑪ The reason for the complaint must be explained and eliminated by the person concerned (e.g. scheme participant or certification body).

⑫ The scheme operator reviews the complaints of the reporting person who submitted the complaint or directly checks the implementation and effectiveness of the measures specified by the person or identified by the scheme operator.

⑬ If the assessment of the effectiveness of the measures (e.g. result of another audit) is not satisfactory, a new cycle of measures (see ⑩) is initiated in accordance with the PDCA cycle (Plan-Do-Check-Act) until the complaint is settled or it is followed up in the same way as the REDcert-EU sanctions procedures.

⑭ Before the complaint procedure is concluded, a summary report is created.

⑮ The parties involved (reporting person as well as the party against whom the complaint is directed) are informed of the results of the investigations within 5 working days after the complaint procedure was concluded.

⑯ If the complaint concerns a scheme participant, the responsible certification body is informed of the results of the investigations to be able to analyse facts relevant to the complaint (e.g. implemented measures) in a regular or commissioned special audit at the request of REDcert.