PEFC RED complaints procedure

To ensure the integrity of our system, as a voluntary scheme recognised by the European Commission under Article 30(4) of the revised Renewable Energy Directive (hereafter “RED II/III”), PEFC has in place RED II/III specific procedures to welcome, investigate, and resolve complaints. In addition to correcting any such issues on the ground, complaints also provide an opportunity to implement corrective and preventive measures and help improve our services.

What is a complaint?

A written expression of dissatisfaction made by any person or organisation related to activities under the PEFC RED II/III scheme, of the PEFC Council, a PEFC RED II/III authorised body, a PEFC RED II/III certified organisation, and a PEFC RED II/III notified certification body. 

Scope of the PEFC RED II/III complaints procedures

The procedure covers complaints related to decisions and activities of the PEFC Council and PEFC RED II/III authorised bodies, including oversight of the handling of complaints lodged against the PEFC RED II/III notified certification body and PEFC RED II/III certified organisation.

Complaints outside the PEFC RED II/III scheme are handled under PEFC GL7/2007, PEFC Council procedures for the investigation and resolution of complaints and appeals"

How to lodge a complaint

All complaints can be lodged to PEFC through one of the following ways:

1. The online form that is available at https://fredii.org/
2. In writing to red@pefc.org, attaching the completed complaint registration form
3. By post, attaching the completed complaint registration form, to the following address: International Center Cointrin (ICC), Route de Pré-Bois 20, 1215 Geneva, Switzerland. 

What should your complaint include?

A complaint should provide contact information of the complainant (person, group of people, organisation or its representative filing a complaint), identify the respondent (a person, group of people, or organisation against whom the complaint is lodged), specify breached requirements, state desired outcomes, give a detailed description, and include verifiable supporting evidence. Hearsay or bad-faith complaints will not be accepted.

General information

• Personnel handling complaints must declare any conflicts of interest before starting the process and will be excluded from decisions if a conflict exists.
• Substantiated concerns other than complaints can be raised via red@pefc.org.
• The complaint procedure ensures that data and information communicated by the complainant and interested parties as part of the procedure are treated confidentially in accordance with Directive (EU) 2019/1937 (Whistleblower Protection Directive) and General Data Protection Regulation (GDPR). This means that personal data and information related to the complaint shall not be disclosed to anyone beyond the authorised staff members competent to receive or follow up on reports, unless required by Union or national law or regulations of the European Commission, in the context of investigations by national authorities or judicial proceedings, including with a view to safeguarding the rights of defence of the person concerned.
• The lack of cooperation by the complainant may be considered as grounds for discontinuation of the procedure. PEFC will decide if a complaint procedure will be discontinued.

Summary of the PEFC RED II/III complaints procedures

1. Submission

Anyone can submit a complaint to PEFC through the online form, email, or post. Anonymous complaint is accepted and the whistle-blower directives is adhered strictly.

2. Register

Complaint recorded in the complaint/appeal register form, and a staff member assigned, within five working days of the submission of the compliant. The assigned staff member will be responsible for handling the complaint.

3. Receipt

Upon submission of a complaint, the complainant will receive a prompt acknowledgment from PEFC.

4. Initial assessment

Within 5 working days of the complaint's acknowledgement, PEFC will conduct a preliminary review to determine whether the complaint is accepted (proceeding to investigation), rejected (dismissed with clear reasons), or transferred (forwarded to the appropriate authority). If information is missing, the complainant will be contacted for clarification. The complainant will be informed of the outcome of the initial assessment. 

The following complaints will be transferred:

• Complaints related to PEFC RED II/III certified organisations will be forwarded to the organisation's complaint procedure. If unresolved, it may then be escalated to the relevant PEFC RED III notified certification body.
• Complaints related to PEFC RED II/III notified certification bodies will be forwarded to their complaint procedure. If unresolved, it may be escalated to the national accreditation body.

In these cases, PEFC will monitor the process to ensure compliance with the relevant complaint procedures.

5. Investigation

If the complaint is accepted, an investigation will start 45 working days from the initial assessment. The complainant will be informed of the outcome.

6. Resolution

Once the complaint receipt has been acknowledged, the assigned staff member will try to resolve the issues by direct communication with the complainant. If the complaint cannot be resolved, the failure of the direct communication will be confirmed.

If direct communication is not feasible, a group of relevant experts will be convened by PEFC. 

The resolution process shall determine measures to identify the root cause of the complaint and the corrective and preventive actions to permanently eliminate and prevent recurrence.

All parties involved, including the complainant and the respondent, will be informed of the result of the complaint's processing within 5 working days of the group's decision.

If the complainant is dissatisfied with the group's resolution, the complainant may request a reconsideration from the PEFC Council Board of Directors. Their decision is final.

7. Completion of the resolution

All agreed-upon actions from the investigation and resolution must be implemented. Any nonconformities identified during the investigation will be addressed through appropriate corrective and preventive actions.

Substantiated complaints can lead to suspension or termination of the relevant contracts and potential suspension of PEFC RED II/III certification for PEFC RED II/III certified organisation