...General reflections on the research methodology

The publication falls short of analyzing wind turbine manufacturers' due diligence across their entire supply chain...The report is based solely on desk-research from publicly reported information and the results stand risk of being related more to how a company communicates on its due diligence processes rather than assessing actual implementation of the publicly communicated due diligence processes. We would like to comment in detail on the following points made in the report:

2.1 Step 1: Embed responsible conduct in policies and systems

...Siemens Gamesa makes clear statements about the conduct it expects from suppliers in the company's Code of Conduct for Suppliers and Third Party Intermediaries, and its corresponding Booklet for Code of Conduct for Suppliers and Third Party Intermediaries, encompassing a broad scope of human rights topics that can be characterized as one of the most strict in the wind market...

2.2 Step 2: Identify risks of adverse impacts

...Siemens Gamesa implements a risk-based due diligence process to assess compliance with our Code of Conduct, identifying any areas of non-compliance and highlighting opportunities to promote improved performance. This includes systematic screening of new and existing suppliers through background checks and risk assessments associated with the sector and countries of operation...

2.3 Step 3: Take action to cease, prevent or mitigate adverse impacts

...Regarding conflict minerals specifically, Siemens Gamesa implemented its due diligence in partnership with Siemens AG and strictly adheres to what is required by the EU...

2.6 Step 6: Provide remedy where appropriate

...As stated in the Siemens Gamesa Compliance internet page, all complaints coming from the Integrity Hotline are managed by a third-party supplier who ensures the protection of the data and anonymity...