Rules of Procedure for Complaints and Reports

January 2024

At Johns Manville, we know that by doing good, we will do well. That is why, during the course of our more than 160-year history, we have built a tradition of conducting business with honesty and integrity, adhering to applicable laws wherever we operate. To live up to this commitment, Johns Manville strives to identify, prevent, and minimize violations of laws, our Code of Conduct, and our policies and procedures. Recognizing that reporting actual or potential violations of the law or our policies is key to ensuring we uphold our values, Johns Manville maintains several effective channels for submitting complaints and reports.

This document, developed pursuant to various Supply Chain Due Diligence (SCDD) laws including the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz - LkSG), explains the main features of Johns Manville’s complaints procedure as it relates to reporting actual or suspected human rights or environmental violations, including how such reports are handled and remediated.

What kind of complaints and reports can be submitted?

In connection with SCDD laws, you can report human rights and environmental violations arising from Johns Manville’s practices within its own business operations, as well as those identified in our supply chain (e.g., at the operations of our direct and indirect suppliers).

Examples of human rights violations include:

  • Use of forced or child labor
  • Restrictions on freedom of movement
  • Restrictions on freedom of association (prevention or ban on forming or joining trade unions, ban on the right to strike, ban on forming works councils)
  • Withholding of wages
  • Inadequate occupational health and safety measures
  • Discrimination: Statements, actions or omissions that physically, directly or indirectly, intentionally or unintentionally disadvantage a person in employment on the basis of certain criteria (e.g. national and ethnic origin, social origin, skin color, gender, religion or belief, political opinion, health status, mental ability, age, sexual identity or sexual orientation)
  • Violations of property rights: unlawful eviction or seizure of land, forests and waters
  • Human rights violations by security forces

Examples of environmental violations include:

  • Deliberate or accidental contamination of water, soil, or air
  • Improper handling or storage of environmentally hazardous substances leading to leakage
  • Improper waste disposal
  • Lack of information on sources of danger
  • Unauthorized release of substances that permanently change the chemical or physical composition of a body of water, the soil or the air

How can complaints be reported?

Johns Manville employees, customers, business partners, and other third parties who wish to report concerns relating to the LkSG or any other SCDD laws can do so via the Berkshire Hathaway Ethics and Compliance Hotline (the Hotline), or at:

Johns Manville
Attn: Senior Global Compliance Counsel
12th Floor
717 17th Street
Denver, CO 80202

Who can submit reports?

All employees, customers, business partners, and other third parties parties who wish to report concerns of human rights or environmental violations relating to the economic activity of Johns Manville can submit reports via the channels listed above.

Can I submit a report anonymously?

Yes, where local law permits. However, we strongly urge reporters to provide contact details to facilitate processing the report. Johns Manville aims to foster and promote an environment of openness where employees feel comfortable speaking up, and therefore recognize that protecting reporters is of paramount importance. We keep reports and the identities of reporters confidential to the greatest extent possible, and strictly prohibit retaliation against anyone who reports a suspected violation in good faith.

If you wish to remain anonymous, please consider taking the following precautions to protect your identity:

  • Do not provide any personal information that could be used to identify you, such as your name, title, or relationship to the suspected perpetrator.
  • Use an anonymized email address.
  • Use your personal (not work-issued) device and internet connection.

How will my report be handled?

Johns Manville treats all reports confidentially to the greatest extent possible, regardless of how the report is made. The identity of the whistleblower and any other persons named in the complaint is kept confidential throughout the entire investigation and remediation process. Please note, however, that Johns Manville may be legally required to disclose your identity to investigating authorities in the event of criminal prosecution or as required by local law.

Only the Director of Internal Audit, the Senior Global Compliance Counsel, the Johns Manville organizational unit responsible for investigating the case, and, if applicable, the persons responsible for the decision and implementation of the measures to be taken have access to the report and any personal data provided with the notice. All such persons are trained to conduct impartial, independent investigations and comply with data protection regulations to protect the rights of all concerned parties.

How am I protected as a whistleblower?

Johns Manville is committed to protecting whistleblowers who submit reports in good faith. Discrimination, punishment, intimidation, reprisals, or any other form of retaliation for good faith reports of actual or suspected misconduct will not be tolerated. This commitment is reinforced by our annual Code of Conduct training and ad hoc/role-specific targeted trainings.

Your report, personal data, and any other messages or documents transmitted in the context of a complaint will always be treated as confidential, and your identity will not be disclosed to the greatest extent permitted by applicable law.

Nevertheless, if you believe you have been discriminated against, intimidated, or otherwise disadvantaged as a result of reporting concerns of possible human rights or environmental violations, contact or submit a subsequent report via the Hotline; such reprisals will be investigated in accordance with the procedures outlined above and, if substantiated, may result in additional consequences under applicable employment or contact law.

What happens after I submit my complaint?

  • Receipt and acknowledgment: Receipts of reports submitted by email, telephone, or post will be acknowledged by the Senior Global Compliance Counsel within 6 working days. Reports submitted via the Hotline are immediately acknowledged by the system.
  • Initial review: All LkSG-relevant reports are first evaluated by the Director of Internal Audit and the Senior Global Compliance Counsel to validate whether it contains sufficient information and properly falls within the scope of the LkSG or other SCDD laws.
    • If your report is not within the scope of the LkSG, the Director of Internal Audit will notify you with a brief explanation and identify other resources or points of contact as appropriate.
    • If the subject of the report falls within the scope of the LkSG but does not contain sufficient information to investigate the allegations, the Senior Global Compliance Counsel will attempt to contact you to clarify or gather additional information. If it is not possible to contact you, or you do not provide the information necessary for an investigation, the case will be closed.
  • Investigation: In-scope complaints will be investigated by or at the direction of the Senior Global Compliance Counsel, while respecting confidentiality and data protection requirements. Allegations that cannot be substantiated will be closed at this stage.
  • Remedial and follow-up measures: Substantiated allegations will be addressed with appropriate corrective actions, such as improved processes, training, and disciplinary measures. If the claim relates to the behavior of a business partner, Johns Manville will endeavor to work with the partner to bring their practices into compliance, and if necessary we will resort to contractual remedies up to and including termination. If you are directly impacted by any of the corrective actions and doing so does not violate data protection regulations, confidentiality agreements, and the like, we will inform you of such measures.
  • Closeout: You will be notified once we have completed our investigation. Because the processing time largely depends on the facts and circumstances of the allegation, we cannot guarantee a specific turnaround time.
  • Documentation and reporting: Johns Manville maintains records of all reports and documents its investigation findings. Additionally, senior management is notified of all substantiated reports on a quarterly basis.