Sustainable Resources
Verification Scheme GmbH
Schwertberger Straße 16
53177 Bonn
Germany
E-Mail: info@sure-system.org
Phone.: +49 (0) 228 3506 150
Fax: +49 (0) 228 3506 280
Complaints
Conflict resolution and the investigation of complaints are essential for SUSTAINABLE RESOURCES Verification Scheme GmbH in order to ensure the reliability and integrity of the SURE-EU scheme.
Protecting the SURE-EU scheme from misuse is important to ensure that those who have invested time and resources in complying with the requirements of the SURE-EU scheme are reliably identified and their interests protected. SURE is interested in resolving conflicts through dialogue with the parties concerned before initiating formal proceedings.
What can be considered a complaint?
A "complaint" is a statement by an interested party that expresses dissatisfaction and is associated with a claim to the system provider SURE.
Complaints of any kind can be an indication of suspected violations or vulnerabilities in system participants, certification bodies and the certification system itself, and trigger additional controls. SURE has set up a complaint management system for this purpose.
The prerequisite for investigating a complaint is objective evidence and as much and concrete information as possible. A complaint based solely on hearsay or rumours is not sufficient for further investigation by SURE.
Complaints are inadmissible if:
- the requirements for form and content are not met. This includes complaints and objections that are not sufficiently supported by objective and sufficient evidence necessary to obtain a clear idea and understanding of the situation at hand.
- the complaint is aimed at adjustments to the recognised SURE-EU scheme.
- the complaint is aimed at amending sanctions imposed by SURE for violations or violations of SURE requirements.
- the reason for the complaint does not explicitly refer to the SUSTAINABLE RESOURCES Verification Scheme GmbH or to activities carried out under SURE.
How can a complaint be submitted to SURE?
The complaint must be submitted in writing, including all verifiable information, to the office of SURE GmbH, clearly marked as a complaint, by post or e-mail (ims@sure-system.org). The prerequisite for investigating a complaint is objective evidence and the most comprehensive and concrete information possible. Of course, an anonymous complaint is also possible. Please use the contact form for anonymous messages.
Postal address
SUSTAINABLE RESOURCES Verification Scheme GmbH
Schwertberger Str. 16
53177 Bonn
Germany
Telefon: +49 228 35 06 150
Appeal procedure (summary) and process
Any complaint that meets the formal and substantive requirements will be recorded, analyzed, and followed up in accordance with Figure 1.
The individual steps of the complaint procedure are carefully documented by SURE.
The complaint procedure ensures the confidentiality and protection of persons who report violations or file complaints. In accordance with Directive (EU) 2019/1937, the identity of the whistleblower shall not be disclosed to anyone outside the staff responsible for receiving or following up on reports without the whistleblower's express consent. This also applies to any other information from which the identity of the whistleblower can be directly or indirectly inferred (Chapter 5, Article 16(1)). By way of derogation from paragraph 1, the identity of the whistleblower and any other information referred to in paragraph 1 may only be disclosed if this is necessary and proportionate under Union or Member State law in the context of investigations by national authorities or court proceedings, including in order to safeguard the whistleblower's rights of defense.
The whistleblower and, where applicable, other parties involved (e.g., competent authorities or the EU Commission) shall be informed of the outcome of the investigation of the grounds for complaint.
Figure 1: Steps in the SURE complaint procedure
The sequence shown in the diagram above looks like this in detail:
(1)
The reporting person has all communication channels at his disposal to submit his complaint to the system provider: e-mail, fax, letter by post. Above all, we would like to expressly point out the possibility of anonymous contact via the SURE website.
(2)
The scheme provider shall decide whether the complaint lodged meets the definition of the scheme. If this is the case, the receipt of the complaint is documented and a progress report is drawn up, in which all further actions and incidents related to this complaint are recorded chronologically and linked to the relevant information and supporting documents. As part of an initial analysis of the complaint, the following is systematically determined and documented:
- the complainant (including contact details)
- Grounds of appeal (information about the companies involved, types and quantities of biomass/biomass fuels or electricity/heat, deadlines and other details)
- possible causes of the complaint (if they can be determined with certainty at this time)
- If applicable, the scope of the complaint regarding the integrity of the SURE system
(3)
The complaint is understandable and admissible in accordance with the SURE Guidelines for Complaints.
(4)
If the complaint is not sufficiently understandable, the complainant will be contacted and an attempt will be made to obtain the missing information from the complainant's point of view.
(5)
SURE maintains a register of complaints received and measures taken, which ensures a transparent procedure to reduce conflicts of interest and the possibility of monitoring.
(6)
If the complaint is sufficiently substantive and convincing, the complainant shall receive a letter within five working days acknowledging receipt of the complaint, assuring him that the complaint will continue to be dealt with and that he will receive information about the progress.
(7)
In order to ensure transparency, SURE shall be required to provide the Commission with a summary of the registered complaints as part of its annual reporting.
(8)
Possible conflicts of interest are analysed.
(9)
If internal conflicts of interest are identified, a management decision shall exclude them. (e.g. the complaint is directed against an employee of SURE who is relieved of the handling of the complaint by direction of the management).
(10)
The system provider shall determine measures to permanently eliminate the cause of the complaint.
(11)
The reason for the complaint must be explained and eliminated by the person concerned (e.g. scheme participant or certification body).
(12)
The system provider shall examine the complaints of the person who submitted the complaint or shall directly examine the implementation and effectiveness of the measures indicated by the person or initiated by the system provider.
(13)
If the effectiveness of the measures (e.g. the result of a further audit) is not satisfactory, a new cycle of measures (see 10) is initiated under the PDCA cycle (Plan-Do-Check-Act).
(14)
A summary report shall be drawn up before the conclusion of the appeal procedure.
(15)
The parties involved (complainant and the person against whom the complaint is directed) shall be informed of the outcome of the handling of the complaint.
(16)
If the complaint concerns a system participant, the responsible certification body will be informed of the result of the handling of the complaint in order to be able to investigate complaint-relevant facts (e.g. implemented measures) in a regular or commissioned special audit at the request of SURE.
