complaint and whistleblowing procedure

We are committed to ensuring the integrity and credibility of the SCH2 EU RFNBO Voluntary Certification Scheme (VCS). If you believe there has been non-conformity with the scheme’s rules, unethical behavior, or procedural errors by economic operators, certification bodies, or other stakeholders, you can submit a formal complaint or confidentially report concerns as a whistleblower.

Submissions are made exclusively via the independent online form and portal to access and manage the submission. The SCH2 complaints/whistleblowing portal is operated by BeCompliance (BeForms), an independent third party provider. BeCompliance acts as data processor under the LGPD (General Personal Data Protection Law), while CCEE is the data controller. BeCompliance’s role is limited to secure intake, time stamped registration, and encrypted transfer of submissions to designated CCEE case managers; it does not triage, investigate, or decide cases.

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The SCH2 complaints/whistleblowing portal is operated by BeCompliance (BeForms), an independent third party provider. BeCompliance acts as data processor under the LGPD (General Personal Data Protection Law), while CCEE is the data controller. BeCompliance’s role is limited to secure intake, time stamped registration, and encrypted transfer of submissions to designated CCEE case managers; it does not triage, investigate, or decide cases.

Access is restricted under a data processing agreement that defines confidentiality, retention, and audit rights. The platform supports anonymous reporting, evidence upload, with all cases handled according to the CCEE/SCH2 procedure and timelines. BeCompliance maintains ISO 27001 and ISO 27701 certifications.

The portal provides time stamped intake, optional anonymity, and secure transfer to CCEE case managers; BeCompliance does not assess or decide cases. 

Alleged breaches by Economic Operators or Certification Bodies of SCH2/EU RFNBO rules (energy qualification, GHG methodology, mass balance/traceability), auditor independence, or serious misconduct (e.g., fraud, corruption). Commercial disputes or matters unrelated to SCH2 are out of scope.

Complainants must provide: type of submission (complaint/grievance/whistleblowing), parties involved, facts (what/where/when), the relevant SCH2/EU RFNBO requirement (if known), and supporting evidence (documents, data, records, or witness statements). Incomplete submissions may be deemed inadmissible or returned for clarification.

process & timeframes (IR 5(3)(c)):
1.    Receipt & acknowledgement (within 5 business days).
2.    Admissibility & scope check (within 10 business days of acknowledgement).
3.    Preliminary assessment (within 20 business days of acknowledgement).
4.    Investigation (up to 90 days; extensions in 30 day increments with written notice).
5.    Decision & notification (within 15 business days after investigation closes).
6.    Appeal (submit within 15 business days; reviewed by personnel independent of the original decision; final decision within 45 days).


Conflicts of interest are screened; conflicted people are recused. Appeals are reviewed by personnel independent of the original decision; instructions are provided with the decision notice.
 
Consequences:
•    EOs: certificate suspension, withdrawal, denial, termination; corrective actions with deadlines; notification to other schemes where applicable.

•    CBs/Auditors: suspension/withdrawal of approval; referral to the accreditation body; enhanced oversight or retraining.

•    Transparency: prompt updates to the certificate database and publication of aggregated Major/Critical NCs and action plans.
Protection & confidentiality:
Reports may be anonymous. People reporting in good faith are protected under Directive (EU) 2019/1937. Identities and case data are handled confidentially; retaliation is prohibited.
Register & reporting:
CCEE keeps a register of all complaints and includes a summary in its annual activity report to the European Commission. Upon request by the Commission or a Member State, CCEE provides all documents related to any complaint and its handling. Records are retained for ≥ 5 years (or longer if required).