Harry,
Your opening jab at Air Berlin suggests you don't like a bit about this whole thing.
Like I said unless ICAO adds "Employee Representation" section to USOAP Safety Audits, audits and ratings are irrelevant.
Bluntly put your suggestion about internal reporting is like saying a domestic violence victim should report to spouse to resolve issues. Never works.
Employees thinking about complaining outside the regulatory regime speaks volumes, needs lot of retrospection.