Complaint system

1.        Introduction

As a globally active company[1], we are obligated to act responsibly and within the legal parameters. The complaint system is a major component of the Takko Compliance Management System, and it provides the relevant reporting channels for recognising risks with regard to human rights and environmental protection, as well as compliance violations.

This code of procedure describes the company’s internal complaint system pursuant to § 3 para. 1 no. 7 in conjunction with § 8 LkSG.

2.        Purpose

The complaint procedure offers whistleblowers the opportunity to disclose risks pertaining to human rights and environmental protections, as well as violations of obligations to adhere to human rights or environmental protections.

3.        Purview

Whistleblowers may be:

·        Staff (such as employees or contractors)

·        Business partners (such as suppliers, service providers, and cooperation partners)

·        Indirect suppliers

·        Customers

4.        Complaint procedure

Takko offers whistleblowers various reporting channels to submit tips. Whistleblowers can contact the following persons at any time:

·        Supervisors

·        Internal confidants

·        Compliance personnel

Whistleblowers can contact the Compliance Officer as follows (including anonymously):

·        Via e-mail: compliance@takko.de

·        Via post: Takko Fashion GmbH, Compliance Officer, Alfred-Krupp-Str. 21, 48291 Telgte

·        Via the web-based system at: company.takko.com/verantwortung

This platform in particular ensures the whistleblower’s anonymity.

After the complaint system has received the complaint, the whistleblower will receive access credentials for the complaint system. This will make it possible for the whistleblower to check on the status of the complaint at any time. Takko will use this reporting channel to answer any questions the whistleblower may have concerning the processing of the case, and to obtain any further information.

After receipt of the complaint, the responsible Compliance employee will be notified that the complaint has been received. Takko will notify the whistleblower of receipt of the complaint within five business days.

The responsible Compliance employee will assess incoming complaints for plausibility. The Compliance employee will carefully assess each complaint, and will work to resolve the issue objectively and impartially. The investigation is always confidential and is solely limited to those persons required to resolve the issue. The Compliance employee can hold confidential discussions with employees, service providers, or other persons instrumental to the investigation of the matter.

The Compliance Officer will then assess the result and decide whether there is a risk or a violation concerning human rights and environmental protections. In the event of such a risk or violation, Takko will take the appropriate corrective actions. Takko will notify the whistleblower hereof no later than three months upon receipt of the complaint.

5.        Protection of whistleblowers from reprisals

Takko is obligated to ensure confidentiality and the protection of whistleblowers. It is in Takko’s interest to identify and put an end to misconduct, implement suitable measures, and prevent long-term risks and violations of human rights and environmental regulations.

Takko ensures the protection of whistleblowers’ identity throughout the entire processing of a complaint, provided the whistleblower requests anonymity. Takko undertakes no measures to identify a whistleblower.

Takko abides by these instructions, as this is the only way Takko can counteract and put an end to violations of humans rights and environmental obligations as well as compliance violations early on.

In the event that the complaint system should be abused, Takko reserves the right to take legal action or disciplinary measures against whistleblowers. The complaint system should only be used conscientiously and responsibly.

6.        Evaluation and improvement

Takko evaluates the complaint system’s needs for improvement at regular intervals and as needed.

Updated: 01/01/2023

[1] Takko Fashion GmbH and all affiliates as defined by §§ 15 et seq. AktG