Better Biomass has developed and is maintaining its certification system through a multistakeholder process. Transparency, openness and decisions based on consensus are core values for the Better Biomass scheme management. Therefore, Better Biomass is very committed to solving conflicts trough dialogue with the affected parties as the preferred solution. If the dialogue between conflicting parties does not solve the conflict, a formal procedure as stated below will follow.
What can be accepted as complaints
The Better Biomass scheme management deals with complaints about the functioning of the committees,
the implementation of the committees’ activities and the incorrect and/or unlawful use of
certification marks by third parties or any other complaints against economic operators or certification bodies. Complaints about (decisions of) certification bodies which are licensed for Better Biomass shall be submitted first to the respective certification body through their complaints procedure.
Complaints can be filed with Better Biomass by any party (individuals or organisations) that is affected by activities or decisions of Better Biomass or has a material interest in the activities of Better Biomass such as certificate holders and their employees, Certification Bodies and their employees, auditors and third interested parties (e.g. competent authorities, NGOs, community groups and other stakeholders).
Complaints are handled according to the procedures described in Chapter 9 Complaints and interpretations of the NEN Scheme Management Manual. The following specifications regarding the complaints procedure apply, in addition to these procedures.
Receipt and evaluation
The Better Biomass scheme management will evaluate all received complaints on the admissibility of these complaints and in relation to the following criteria:
Confidentiality and anonymity
Better Biomass will maintain confidentiality of the complaint and the complainant as much as possible and will not share more details than absolutely necessary with those involved for effective handling of the complaint. However, in order to resolve the complaint, details will need to be disclosed to those involved in the complaint and/or its handling.
If the complainant wishes to remain fully anonymous throughout the entire conflict resolution process, the complaint shall be explicitly be labelled Anonymous. Since Better Biomass promotes open dialogue, this is not the preferred option and the complainant shall give a good reason for this (such as risk of retaliation). If anonymity is granted, all parties involved in the conflict resolution process will ensure that the identity of the complainant will not be disclosed throughout the process. This may however affect some of the possibilities to resolve the complaint.
Confirmation of receipt
The complainant will be informed in writing without delay about the receipt of their complaint. The Better Biomass scheme management will decide if the complaint is accepted within 10 working days upon receipt of the complaint and will inform the complainant about the decision.
Handling of complaints
Complaints shall be assigned on a case-by-case basis to a complaints manager by the Better Biomass scheme management. If anonymity is granted, the complaints manager will handle accordingly. The complaints manager shall take any measures necessary to avoid retaliation against persons who report infringements or lodge complains. Additional staff time to handle the complaint shall be made available by the parties involved. Accepted complaints will be analysed, investigated and decided on impartially and unbiased on a case-by-case basis by the Better Biomass scheme management, or if relevant, by the NEN Scheme Management committee. Handling of the complaints will follow the procedure as specified in section 9.2 of the NEN Scheme Management Manual.
In the course of investigating the reason for the complaint, Better Biomass is entitled to contact the parties and stakeholders affected and to ask for supporting evidence, documentation or statements in order to attain a sufficient understanding of the situation and to ensure that all parties involved can explain their position regarding the complaint. Better Biomass is also entitled to schedule an independent assessment to gather further evidence. Better Biomass will react to any information and evidence received within 10 working days of receipt.
The Better Biomass scheme management is very committed to ensuring balanced and effective protection of persons who report infringements or log complaints in good faith in accordance with Directive (EU) 2019/1937. This means that in such cases dedicated impartial resources will be allocated for providing timely feedback to whistle-blowers. The topic is put on the agenda of the various committees, as well as internal meetings, to create awareness and discuss the most appropriate courses of action if such cases would present themselves.
Completion of the complaint process
Any result and decision will be communicated to the complainant by the Better Biomass scheme management without delay. The handling of the complaints shall be completed within 90 days of formal receipt. Based on the decision or any evidence received during the analysis of the complaint, Better Biomass is entitled to make provisions for certification audits or request that the Certification Body conducts surveillance audits of the affected certificate holder. Non-conformities found by the scheme manager as result of a complaint shall be reported to the Certification Body and handled according to the procedures for non-conformities during surveillance audits.
Better Biomass keeps a register of all complaints and provide a summary of those complaints in the annual activity report.