Commitment to addressing malpractice

What kinds of reports can I make via the whistleblowing system?

This portal allows you to confidentially and, if desired, anonymously submit reports of actual or suspected violations of laws or internal rules as well as other malpractices and undesirable trends.

We specifically accept reports in the following categories:
Corruption/ bribery; theft; anti-competitive practices/ anti-trust law violations; severe violations of the VGG (Collecting Societies Act)/ GEMA regulations or of contract and licensing law; violations of data protection/ information security; ethical malpractices/ discrimination.

You will receive detailed information on the possible categories of a report during the reporting process.

For general questions concerning GEMA, GEMA membership or the licensing of music use, please contact the respective contact persons. You can find these here: https://www.gema.de/kontakt/

What is the process for submitting a report? What is a postbox and how do I set up one?

To submit an anonymous or personalised report, start by clicking the “Submit Report“ button at the top of our introduction page.

There are 4 steps to the report process:

1. First, you will be asked to read some information on the protection of your anonymity and to respond to a security query.
2. On the following page, you will be asked about the category of your report.
3. On the report page, you can elaborate on your report in your own words and answer questions about the incident by simply selecting responses. You can type up to 5000 characters into the free text field, which corresponds to a full A4 page. You may also submit a file of up to 5 MB to support your report. Please do bear in mind that documents can contain information about the author. Following the sending of your report, you will receive a reference number as confirmation that you have forwarded this report.
4. Please subsequently set up your own secured postbox. You will receive feedback from us via this postbox, including answers to questions and information about the progress of your report.

If you already have a secured postbox, you can access it directly via the ”Login“ button. First, you will have to answer a security query.

If you do not enter any data from which conclusions about your person can be drawn, the technology of the BKMS^® System will protect your anonymity.

Please rest assured that we are interested only in the incident you are reporting. Malpractices should be revealed, and financial losses prevented.

How do I receive feedback and remain anonymous at the same time?

The overriding principle of the BKMS^® procedure employed here is the protection of the whistleblower. The system's anonymity protection function is certified by an independent body.

When you set up your secured postbox, you choose your pseudonym / user name and password yourself. These user credentials are not visible to anyone except yourself. Your report is kept anonymous through encryption and other specialised security measures. If you submit your report anonymously, you do not have to provide any personal information. Do not submit any information that can be traced back to you. Please do not use a computer provided by your employer to submit your report.

Via the secured postbox, an examiner will give you feedback about the further processing of your report or ask you questions if some details are still unclear - you remain anonymous throughout the dialogue. We are interested in reports to avoid damage, not in you as a whistleblower.

Who processes my report? What is the process for an investigation?

Your report will be sent to the central Compliance team (Chief Compliance Officer, central Compliance Manager and, in each case, a deputy). The whistleblower receives a confirmation of receipt. In case of questions, the examiner will contact the whistleblower via the secured postbox.

The circumstances described in the report will be immediately and comprehensively investigated in order to comply with statutory deadlines and to give the whistleblower prompt feedback – insofar as possible.

Internal investigations may only be carried out when there is enough initial suspicion of specific circumstances relating to the company. Investigations are carried out with the greatest possible confidentiality while observing the principles of data protection and protecting anonymity.