alliance for grievance mechanisms

in supply chains
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our story

about the
spanish project

eight collaborative working groups started

Following the request made during a two-day multi-stakeholder workshop in Madrid in June 2023, we have been working on developing all the elements for a single sector-wide grievance mechanism framework for fresh fruit and vegetable supply chains from Spain – a concept to be expanded to other geographies and sectors.

Approximately 50 experts from 20 organisations – retailers, traders, Spanish producers and producer organisations, NGOs, and trade unions – began working together in these eight working groups:

working group: legal

how to align and integrate all relevant legal requirements,
in particular the new spanish whistle blower protection law?

The Working Group Legal has developed a set of deliverables that will help to ensure the legal compliance of the appellando system.

the deliverables

  • An assessment of whether a single helpline can cover the Ley 2/2023 and the German LkSG/EU CSDDD. This will help to ensure that the appellando system is compliant with both sets of legislation.
  • An assessment of any potential conflicts between the appellando system and labor law. This will help to ensure that the appellando system does not violate any workers’ rights.
  • An assessment of how two parallel systems could exist next to each other. This will help to ensure that workers have access to the appellando system, regardless of where they are located.
  • A review of the OECD’s recommendations on aligning legislation between Germany, Spain, and the EU. This will help to ensure that the appellando system is compliant with the latest international standards.
  • Rules to observe EU General Data Protection Regulation (GDPR) in the appellando system. This will help to ensure that the personal data of workers is protected.
  • Rules that protect employers against unjustified claims and the system against fraud. This will help to ensure that the appellando system is fair to all parties involved.

working group: governance

who shall decide what and when?

The Working Group Governance has developed a set of deliverables that will help to ensure the effective governance of the appellando system.

the deliverables

  • A list of all stakeholders by category and function, including strategic partners. This will help ensure that all stakeholders are represented and that their interests are considered.
  • A distinction between Spanish fruit and vegetables and other geographies and products. This will help to ensure that the needs of all stakeholders are met also beyond Spain for the expansion.
  • The identification of stakeholders with environmental interest. This will help to ensure that the environmental impact of the appellando system is considered.
  • A decision on the type of legal entity and decision-making structure. This will help to ensure that the appellando system is structured in a way that is effective and efficient.
  • The definition of a business model to fund the operation and expansion of the appellando system. This will help to ensure that the appellando system is financially sustainable.
  • The description of an internal complaints procedure. This will help to ensure that there is a clear process for handling complaints to the appellando system itself.
  • A formal and contractual relationship with all stakeholders has been established.
  • The language and internal communication infrastructure have been adapted to the operation of the system and continuous improvement.
  • The legal entity has been established, and the decision-making structure is functional.
  • The internal complaints procedure has been reviewed.

working group: needs assessment

how to meet the needs of all workers (rightsholders)?

The Working Group Needs Assessment has developed a set of deliverables that will help to improve the understanding of the needs of workers across the industry.

the deliverables

  • A list of recommendations on which channels with which information works, which do not. This will help to ensure that the information about the appellando system (harmonized grievance mechanisms and access to remedy) is reaching the right people in the right way, and we know which channels they prefer to use to address grievances.
  • A target list of the relevant groups and their representation to collect sufficient feedback through interviews. This will help to ensure that the needs of all workers are being considered.
  • A manual and questionnaire for the interviews, and the questionnaire has already been tested. This will help to ensure that the interviews are conducted in a consistent and effective manner.
  • A list of successful approaches and a list of failures with reasons, that are collected from other grievance mechanism systems and worker survey services. This will help to form the design of the new appellando system. The survey of all relevant groups has been completed. This will provide a comprehensive understanding of the needs of workers.
  • A starting concept to approach and connect workers to the system and encourage them to raise a complaint if they need to. This will help to ensure that workers are aware of the appellando system and that they are encouraged to use it.

working group: supply chain transparency

how to balance transparency and confidentiality?

The Working Group Supply Chain Transparency has developed a set of deliverables that will help to improve the transparency of supply chains across the industry.

the deliverables

  • Agreement on the use of a “Global Farm ID” to identify any farm and site uniquely. This will help to ensure that all farms and operators are identifiable and traceable.
  • Definition of the minimum requirements for traceability to connect the supply chain in cases of grievances. This will help to ensure that all stakeholders in the supply chain can be identified and contacted in the event of a complaint.
  • Description of the necessary processes and rules, and how they can be monitored. This will help to ensure that the traceability system is effective and that the rules are being followed.
  • Implementation of a first version of a fit-for-purpose traceability system with adequate and agreed confidentiality rules. This will help to ensure that appropriate traceability systems are in place and that the confidentiality of data is protected.

working group: protocol for case handling

how to receive, process and report complaints and grievances?

The Working Group on Protocol for Case Handling has developed a set of deliverables that will help to improve the handling of complaints across the industry.

the deliverables

  • A list of objective criteria to approve any operator/IT solution. This list will be based on the requirements of the German Anti-Trust Authority and will ensure that all operators are using a consistent and transparent approach to the approval of new solutions.
  • A list and classification of complaints. This list will include a description of the different types of complaints that are received, as well as the rules on how to handle each case. This will help to ensure that all complaints are handled in a consistent and fair manner.
  • A description of a case handling protocol. This protocol will provide a step-by-step guide on how to handle complaints, from the initial receipt of the complaint to the final resolution. This will help to ensure that all complaints are handled efficiently and effectively.
  • A definition of case reporting criteria. This definition will specify the information that operators must collect and report on each complaint. This will help to ensure that the industry has a clear understanding of the nature and volume of complaints that are being received.
  • An IT interface description. This description will specify the technical requirements for the exchange of data between operators. This will allow operators to share information about complaints in a secure and efficient manner.

working group: communication and promotion

how to raise awareness and build trust among all stakeholders?

The Working Group Communication & Promotion has developed a set of deliverables that will help to improve the communication and promotion of the project across the industry.

the deliverables

  • A list of each target group, their information needs, and language. This list will help to ensure that the project’s communication is targeted and relevant to the different stakeholders.
  • The establishment of other relevant communication channels, such as social media and events, in addition to a website and newsletter. This will allow the project to reach a wider audience and engage with stakeholders in a variety of ways.
  • A media and content plan with responsibilities and targets. This plan will ensure that the project’s communication is coordinated and effective.
  • Key language and argumentation for each target group, including FAQs. This will help to ensure that the project’s communication is clear, concise, and persuasive.
  • A strong brand and claim. This will help to build awareness of the project and its goals.

working group: investigation

who shall be eligible to investigate under which procedure?

The Working Group Investigation has developed a set of deliverables that will help to improve the investigation of complaints across the industry

the deliverables

  • A list of objective criteria to approve any investigator. This list will be based on the requirements of the German Anti Trust Authority and will ensure that all investigators are using a consistent and transparent approach to the investigation of complaints.
  • A definition of a protocol for investigation. This protocol will provide a step-by-step guide on how to investigate complaints, from the initial receipt of the complaint to the final resolution. This will help to ensure that all complaints are investigated efficiently and effectively.
  • A list of cases and circumstances that define how the costs for investigation shall be covered. This list will help to ensure that the costs of investigation are fair and transparent.
  • A list of criteria and samples where we encourage and/or require the collaboration of investigators. This list will help to ensure that investigations are conducted in a coordinated and efficient manner.

working group: remediation

who shall be eligible to work on solutions for remediation under which procedure?

The Working Group Remediation has developed a set of deliverables that will help to improve the remediation of complaints across the industry.

the deliverables

  • A list of cases and circumstances that define how the costs for remediation shall be covered. This list will help to ensure that the costs of remediation are fair and transparent.
  • A list of objective criteria to approve any remediator. This list will be based on the requirements of the German Anti Trust Authority and will ensure that all remediators are using a consistent and transparent approach to the remediation of complaints.
  • A definition of a protocol for remediation with reference to Spain. This protocol will provide a step-by-step guide on how to remediate complaints, from the initial receipt of the complaint to the final resolution. This will help to ensure that all complaints are remediated efficiently and effectively.
  • A list of criteria and samples where we encourage and/or require the collaboration of remediators. This list will help to ensure that remediations are conducted in a coordinated and efficient manner.
  • We have implemented a first version of a fit-for-purpose protocol for remediation, including rules for collaboration among different remediators.

our story

eight collaborative working groups

retailers, traders, Spanish producers and producer organisations, NGOs,
and trade unions

All working groups met virtually every two weeks between July 2023 and March 2024. All were held bilingual Spanish-English.
Participating organizations included:

Albenfruit, ALDI Nord, ALDI SOUTH, Anecoop, AskYourTeam, Campina Verde, CCOO, Coexphal, CONVIVE – Fundación Cepaim, Driscoll’s, Eurogroup España Frutas y Verduras, Greenyard Fresh Spain, Huelva Acoge, Issara Institute, Kaufland, Lidl, Markant, Quality & Adviser, SanLucar Fruit, The Remedy Project, REWE and Ulula

Initial results were presented at the Fruit Attraction trade fair in Madrid, 3–5 October 2023 followed by a panel discussion on the Fresh Produce Forum “German Supply Chain Due Diligence Act – (How) does it work? First exchange of experiences” on the Fruit Logistica trade fair in Berlin, 8 February 2024.

Why Germany-based retailers and why fresh fruit and vegetables from Spain?

Since January 2023, a new German legislation on supply chain due diligence (LkSG) has been in effect. It required Germany-based buying groups with more than 3,000 employees (in Germany) to set up complaint procedures that are easily accessible for all workers in their respective supply chains, in particular to vulnerable groups such as migrant workers. The size of obliged companies has dropped in 2024 to 1,000 employees.

With the adoption of the European Corporate Supply Chain Due Diligence Directive (CSDDD, EU 2024/1760) on July 25, 2024, a foundation has been established for corresponding legislation in all EU member states. Starting in 2027, all EU member states are required to implement the EU directive into their national laws.

contact us

our team

Feel free to reach out to our team under info@appellando for any inquiries or support.
We’re here to help and look forward to hearing from you!

Dr. Kristian Moeller

Dr. Kristian Moeller

Managing Director

Nadine Kremser

Nadine Kremser

Office Manager

Angela Schillings-Schmitz

Angela Schillings-Schmitz

Lead Program

Reiko Enomoto

Reiko Enomoto

Training Specialist