Whistleblower Policy

Introduction

Compliance refers to adherence to legal provisions, internal guidelines and ethical standards. As ensuring a transparent and ethical organizational culture is crucial for the safety of our employees, company, and business partners, compliance violations must be identified and reported at an early stage so that appropriate steps can be taken.

This policy aims to create a secure framework for reporting violations and to develop an open corporate culture. It promotes compliance with legal and ethical standards, uncovers and addresses misconduct, protects whistleblowers and is therefore a key component of our commitment to responsible behaviour.

The legal background to this policy is based on the Whistleblower Protection Act (HinschG, Germany) of 31 May 2023, which sets out minimum standards for the protection of individuals who report violations within an organisation.

Who can provide information about violations?

A whistleblower is a person who has knowledge of violations within an organisation and reports them. Therefore, all employees, freelancers and former employees as well as our customers, suppliers and business partners are encouraged to report compliance violations to us.

What violations can I report?

Relevant violations under the Whistleblower Protection Act are acts or omissions that violate the laws, regulations or guidelines which apply to skatedeluxe.

What does this include?

  • General compliance violations Instances of breaching internal company policies, industry regulations, or legal requirements.
  • Corruption and bribery Suspected cases of corruption, bribery or unethical behaviour.
  • Financial fraud and manipulation Manipulation of financial reports, fraud, theft or other unethical financial practices.
  • Discrimination and harassment Cases of discrimination, bullying, sexual harassment or other inappropriate behaviour in the workplace.
  • Environmental and occupational safety violations Violations of environmental regulations, unsafe working conditions or inadequate safety practices.
  • Quality failures Incorrect information about products or services, violations of quality standards or safety requirements.
  • Conflicts of interest Undisclosed conflicts of interest that could affect the integrity of decisions or business practices.
  • Working time and remuneration fraud Manipulation of working time or remuneration records, working time fraud / fraudulent accounting.

What does this not include?

  • Complaints If you want to register a complaint about an item purchased in our online shop or are otherwise dissatisfied, please use our contact options for the service team.
  • Privacy policy Please report violations of data protection regulations, unauthorised data processing or data breaches directly to datenschutz@skatedeluxe.com.

What should a notice of violation contain?

Notes should contain precise information on the following questions:

  • What happened?
  • When / in what period did it happen?
  • At which location / in which area or department did something happen?
  • Which persons are involved?
  • Are there any other witnesses to the incident?

Please make sure to verify all information before submitting a report. It is strictly prohibited to file any reports that contain knowingly false information. To ensure accuracy, please use phrases like "I am sure..." or "I believe..." to indicate the degree of certainty.

How can information be provided?

Compliance violations can be reported to the compliance officer via email, mail, phone, or in person, but an appointment is required for a personal meeting.

  • E-mail: safe_compliance@protonmail.com
  • Phone+49 (0) 3641-7997244
  • Mailing address

    Personal/confidential
    SAFE COMPLIANCE c/o Thomas Woywodt
    skatedeluxe GmbH
    Carl-Pulfrich-Str. 1
    07745 Jena
    Germany

We recommend submitting anonymous reports by mail. They are treated with the same seriousness and scrutiny as reports made by identifiable individuals.

What happens after a report is made?

The receipt of your notification will be confirmed within seven days. We will keep you informed throughout the process by providing timely and appropriate feedback. You will receive final feedback on the results and the measures taken no later than 90 days after submitting the report. All data relating to you and the report will be stored securely and deleted after 3 years.

How will my identity protected? Can I remain anonymous?

The identity of whistleblowers is always protected. It is also possible to remain anonymous. However, feedback can only be provided to anonymous whistleblowers if such a person has provided a means of contacting them.

The Whistleblower Protection Act does not protect the identity of whistleblowers if incorrect information about violations is reported intentionally or through gross negligence (see §9 HinschG). Furthermore, the identity of a person may have to be disclosed to a competent authority due to a request from a law enforcement authority in criminal proceedings or due to a court decision.

What protection is there against reprisals if I report something?

It can be assured that whistleblowers will receive protection from all discrimination or reprisal. Any form of retaliation against whistleblowers will be considered a serious violation of this policy and disciplinary action will be taken.

What happens to personal data?

Your data will be treated confidentially and used exclusively to investigate and follow up on reports following data protection regulations.

Are there any external reporting centres?

In addition to the internal reporting option, there is also the option of sending information directly to the Federal Office of Justice:

BfJ - Federal Office of Justice
Adenauerallee 99 – 103
53113 Bonn
Germany