Any officer, director, employee, consultant or agent of the Company as well as any supplier, contractor or client having noticed a violation should promptly report it.

After the report is submitted, the Designated Person(s) carry out their initial verification within 7 calendar days of the receipt of the report. Then, the Designated Persons decide the composition of the Investigating Commission which shall be in charge of taking the necessary actions to clarify the case.

You can make an anonymous report, but remember that if a report does not contain the name, surname or contact details of the Whistleblower, such a report shall be examined and dealt with to the extent that it contains sufficient information relating to breaches of the law. Reports submitted anonymously by Workers may also result in limiting the detail of feedback on the follow-up actions undertaken by the Company in connection to the Report.

Acting in good faith – acting in the confidence that the information reported is true at the time of reporting and that it is or may be an irregularity, taking into account the best interest of the Company.

People who have made a report in good faith are protected from retaliation.

However! Reporting false information intentionally is prohibited and may be sanctioned.

Each Whistleblower is provided with:

a) identity protection

All persons in the Investigating Commission shall keep confidential the identity of the Whistleblower as well as other personnel revealed.

Any data identifying a Whistleblower may be disclosed only based on his/her prior, express consent – except for disclosing to competent authorities, when such an obligation results from legal provisions.

b) protection against retaliation

Whistleblowers in public interest acting in good faith are protected from any form of retaliation. Retaliation is any action or omission, direct or indirect, occurring in a professional context, which is prompted by internal or external reporting or public disclosure and which causes or is likely to cause harm to the Whistleblower. This includes, but is not limited to: termination of employment, disregard for promotion, unjustified bad treatment, unfavorable change of employment conditions or remuneration, any manifestation of intentional harm to further professional career or reputation or threat of such action.

c) feedback on the actions taken in connection with the report

Whistleblower will be informed about:

• acceptance of the report or rejection of it – within a maximum of 7 calendar days
• the result of the investigation (i.e. whether the law has been violated) and the follow-up actions (i.e. actions taken in connection with the report) – within a reasonable time, not exceeding 3 months from the receipt of the report, and subsequently, whenever there is progress in the investigation, unless the information could affect the relevant investigation.