Compliance

Compliance is not just a technical term for cluetec as a part of the Possehl Group, but an elementary component in our daily activities. ​

That is why trust is essential for cluetecs success as part of an internationally active group of companies. Good cooperation is based on the trust of customers and business partners, employees and the respective local business environment. The prerequisite for this is consistent adherence to high standards of social behavior such as integrity, loyalty and honesty.

​It is our responsibility to create and maintain universally valid basic values of our behavior that go beyond the applicable laws and that should form the basis for every entrepreneurial activity. Therefore, we at cluetec are guided by the Code of Conduct of the Possehl Group. This code forms the framework of responsible conduct for all employees, partners and managing directors.

Code of Conduct

Supplier Code of Conduct

​ Whistleblowing System ​

Possehl Digital offers the possibility to contact an internal, outsourced and independent whistleblower portal in case of suspicion or knowledge of illegal or unethical actions and thus to contribute to the detection of violations of rules. ​

It is possible to report misconduct by employees in our group of companies as well as by our suppliers and service providers with regard to possible violations of the law or actions that are harmful to the company, such as corruption, bribery, fraud, other criminal offences, child labour, slavery, lack of occupational safety, exploitation and discrimination. ​

Whistleblowers will not suffer any disadvantage as a result of making a report. Reports can be made in German and English. Reports can also be made anonymously if desired.

WhistleFox whistleblower portal ​

If you have concrete, justified indications of legal violations or breaches of rules at Possehl Digital or suspect such violations, you have the following options for contacting us:

​• by web form
• by phone: +49 221 2052-547
• by fax: +49 221 2052-1
• by e-mail: c.schork@heuking.de ​

The confidential reporting office (WhistleFox) can be contacted around the clock by web form, e-mail, fax or post and by telephone every working day during normal office hours. ​

The contact person is Dr Christoph Schork, attorney-at-law. ​

Heuking Kühn Lüer Wojtek
Attn. Dr Christoph Schork
Magnusstraße 13
D-50672 Köln ​

In addition, there is the possibility of reporting to official external reporting offices. These are, for example:

• the external reporting office of the federal government at the Federal Office of Justice;
• external reporting offices of the respective federal state;
• specific responsible external reporting offices, e.g. at the Federal Cartel Office.

Please note that the whistleblowing system is not intended for complaints. If you are dissatisfied with regards to the products or services of the Possehl Group, please contact your respective contact person in the company. ​

For information according to the German Supply Chain Duty of Care Act (Lieferkettensorgfaltspflichtengesetz), you can find further procedural information here.