§ 1.The purpose of the procedure

 

Fulfillment of the obligations contained in the Whistleblower Protection Act of 14 June 2024.

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§ 2. Glossary of terms

 

All concepts used in the procedure are described in the Whistleblower Protection Act of 14 June 2024.

 

§ 3. Personal scope

 

Under this procedure, whistleblowers may include:

• employee,

• temporary employee,

• a person performing work on a basis other than an employment relationship, including a civil law contract,

• people who have stopped working,

• candidates for job,

• intern, volunteer, trainee,

• proxy

• shareholder or partner,

• member of the management or supervisory board

• entrepreneur – service provider and supplier with whom the employer has a contract,

• persons performing work under the supervision and management of an entrepreneur

 

 

 

§ 4. Subject scope

 

The procedure applies to reports of violations of the law concerning:

• corruption,

• public procurement,

• financial services, products and markets,

• counteracting money laundering and terrorism financing,

• product safety and compliance with requirements,

• transport safety,

• environmental protection,

• radiological protection and nuclear safety,

• food and feed safety,

• animal health and welfare,

• public health,

• consumer protection,

• protection of privacy and personal data,

• security of networks and IT systems,

• financial interests of the State Treasury of the Republic of Poland, local government units and the European Union,

• the European Union internal market, including public law rules on competition and state aid and corporate taxation,

• constitutional freedoms and rights of a human being and a citizen – occurring in the relations of an individual with public authorities and not related to the areas indicated above.

 

 

§ 5. Methods of submitting reports

 

In order to submit a report, please use one of the reporting channels listed below.

1. Submission by e-mail:

   1. the notification is made by sending a message to the e-mail address: ……,

   2. in the message subject, at the beginning or in the title of the e-mail, must be provided login and password,

   3. only the content of the notification is forwarded to the employer,

   4. the system does not provide information about the e-mail address from which the notification arrived,

   5. Only providing personal data and preferred forms of contact in the message will allow the people receiving reports to contact the whistleblower.

2. Face-to-face meeting:

   1. the whistleblower may submit a request for a direct meeting with the coordinator,

   2. to submit an application, you can choose the submission channel - e-mail or do it in any other official way,

   3. the application should be sent to the coordinator,

   4. the meeting will be organized no later than 14 days after receiving the request,

   5. at the express request of the whistleblower or due to the special circumstances of the case and the need to ensure discretion and confidentiality, the meeting may be organised outside the employer's headquarters,

   6. the meeting will be documented in the form of an audio and video recording or in the form of a protocol reproducing its exact course,

   7. the whistleblower will have the right to check, correct and approve the protocol by signing.

 

 

 

§ 6. Notification requirements

 

1. Information provided by a whistleblower will be considered as notification and will be subject to this procedure if the following general conditions are fulfilled:

• • truthfulness of the report – the whistleblower does not have to have evidence to confirm the information contained in the report, but must have reasonable grounds to believe that the information provided is true at the time of notification,

  • work-related context – the information contained in the notification must have been obtained in a work-related context,

  • categories of violations – the information contained in the notification must concern the violation of law or irregularities listed in § 4 of the procedure.

     

1. The employer does not tolerate false notification – persons making such notification will be subject to disciplinary and civil consequences and a notification will be sent to the relevant judicial authorities.

    

2. Notifications submitted anonymously will not be considered and are not subject to this procedure.

    

3. The whistleblower should ensure that he or she provides the most valuable information possible to enable the investigation to be conducted effectively.

 

 

§ 7. Coordinators and confidentiality

 

1. The employer appoints a coordinator to receive and process notifications, undertake and coordinate follow-up actions and process the personal data of whistleblowers and other persons mentioned in the notification.

    

2. Information on the coordinator’s authorisation and his/her personal data will be announced each time in the form of a notice posted on the notice board at the company’s headquarters.

    

3. Coordinators guarantee that all notifications will be treated with due seriousness and diligence, and that their consideration will be based on the principles of impartiality and objectivity. Respect for the dignity and good name of all persons concerned by the report will be the guiding principle throughout the entire investigation process.

    

4. Coordinators and all other participants in the investigation process are required to take reasonable steps to ensure that all decisions and follow-up actions are based on facts and evidence collected, and not slander and unfounded accusations.

    

5. The process organization of submitting, receiving and processing notifications is intended to prevent any unauthorized persons from gaining access to the information contained in the report.

    

6. The process organization ensures confidentiality and protection of the identity of the person submitting the notification, the person whom notification applies, as well as all other persons whose data appear in the notification.

    

7. Access to the whistleblower’s data and the information contained in the notification is granted by the coordinator only to persons who are necessary to conduct an effective investigation, after receiving from them a written commitment to keep confidential all information obtained during the investigation.

    

8. In any other case, the identity of the reporting person may only be disclosed with his or her express consent.

    

9. Disclosure of whistleblower data may also occur when it is a necessary and proportionate obligation arising from legal provisions in connection with explanatory proceedings conducted by public authorities or preparatory or judicial proceedings conducted by courts, in order to guarantee the rights of defence of the person concerned by the notification.

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§ 8. Follow-up actions

 

The procedure stages after receiving the notification:

 

1. registration of the notification,

    

2. confirmation – within 7 days from receiving the notification, the coordinator will confirm to the whistleblower that the notification has been received,

    

3. feedback – within 3 months, coordinators will provide the whistleblower with feedback on whether or not a violation of the law has been identified and on any planned or undertaken follow-up actions and the reasons for such actions,

    

4. conclusion of the case in the notification register.

 

 

 

§ 9. External notification

 

1. The employer encourages reporting via internal reporting channels in accordance with the principles set out in the procedure.

2. This procedures is not limiting the whistleblowers, who have the option to place an external notification.

3. External notification should be made to:

• • Commissioner for Human Rights,

  • other public authorities, entitled to receive external notifications of violations in the areas being in scope of their activities,

  • institutions, bodies or agencies of the European Union.

1. Detailed information regarding the procedure, principles and forms of making external notification can be found in Chapter 4 of the Whistleblower Protection Act.

 

 

 

§ 10. Validity of the procedure

 

1. This procedure shall enter into force on the date of its announcement.

    

2. The procedure applies to all persons mentioned in § 3 of this procedure, regardless of their position and type of contract.