As a commercial enterprise, we see it as our duty to act in a morally correct and responsible manner.
As a consequence thereof, we have developed a reporting process that internal and external individuals can use to report grievances at The Creative Club.
The process complies with the EU Whistleblower Directive 2019/1937 and thus the Whistleblower Protection Act (HinSchG).
The HinSchG regulates the protection of persons who have obtained information about offences in connection with their professional activity or in the run-up to a professional activity and report or disclose these to the reporting offices provided for under this Act. Persons who are the subject of a report or disclosure and other persons affected by a report or disclosure are also protected.
You can find the full text of the law at https://commission.europa.eu/aid-development-cooperation-fundamental-rights/your-rights-eu/protection-whistleblowers_en
In addition, we have concluded a works agreement with the Works Council on the organisation of the reporting procedure.
What kind of grievances can be reported?
To name a few examples:
- Tax fraud, money laundering, corruption
- Offences in connection with public contracts
- Violation of product and traffic safety
- Environmental and public health hazards
- Breach of consumer and data protection
- Sexual harassment, bullying, violence
It is therefore a matter of abuses that violate EU law and/or constitute serious misconduct or a criminal offence.
In that respect, you are not required to be able to prove the offences. The decisive factor is that you must believe or assume at the time of reporting that the facts reported are true. Information that is demonstrably provided against better judgement or in an abusive manner is therefore not protected.
It is not concerned with personal feedback or questions about our products or the ordering process. Our customer service team will be happy to help. Feedback on a partnership/collaboration or the employment relationship should also be given directly to the contact person or manager.
Who can report a grievance?
The person providing the information may belong to an internal or external stakeholder group of The Creative Club. These are, for example, employees, customers, suppliers or journalists.
How does the reporting process work?
We have installed three reporting channels through which the report can be submitted:
1. Using a digital form for internal & external stakeholders with the possibility to remain anonymous
2. In writing by post to the address below including password and, if requested, contact details to be kept informed about the process; for internal & external stakeholders
The Creative Club
3. Orally to our Chief HR Officer, for internal stakeholders only
A report can also be submitted via the Federal Office of Justice. This means that none of the reporting channels we have set up are used.
As soon as we receive a report via one of these channels, we immediately start checking and analysing the report. This also includes documenting all information in detail and involving the relevant responsible parties.
If we have the contact details of the whistleblower, we will inform them of the progress and outcome or the measures taken.
The investigations are carried out independently and impartially.
Will the person providing the information remain anonymous?
The report can be submitted anonymously to our TCC reporting office using the digital form. However, we would like to point out that we will not be able to inform the person providing the information about the review process and the result.
We would like to emphasise that reports are processed in a strictly confidential, professional and timely manner. The whistleblower can be sure that he or she will not be prosecuted in any way for the report.