REPORTS UNDER WHISTLEBLOWERS PROTECTION ACT

REPORTS UNDER WHISTLEBLOWERS PROTECTION ACT

A Guide to submittion of reports under the Act on Protection of Persons, Reporting Information or Publicly Disclosing Information about Breaches (Whistleblowers Protection Act) of STROYRENT EOOD

This Guide is issued on the basis of Art. 12, para. 5 of Whistleblowers Protection Act and regulates the conditions and procedure under which reports of committed breaches may be submitted, including in case of reasonable suspicions of actual or potential breaches, in or affecting STROYRENT EOOD (hereinafter the "Company").

1. Who has the right to report?

If you are an individual who, in the performance of your work or official duties or in another work context, has received information about a breach in or affecting the Company, you can submit a report. More specifically, you can report a breach under the Whistleblowers Protection Act if you fall into one of the following categories of persons:

• if you are a current employee of STROYRENT EOOD and your information became known during or in connection with the performance of your work or official duties;
• if you are a person working under the supervision or direction of contractors, subcontractors or suppliers of STROYRENT EOOD;
• if you are a person who provides service to STROYRENT EOOD without an employment relationship and/or within the scope of your free profession and/or craft activity;
• if you are a volunteer or intern at STROYRENT EOOD;
• if you are a member of the management or control body of the Company;
• if you are a person whose employment relationship with STROYRENT EOOD is about to begin and the information regarding the breaches was received during the selection process or other pre-contractual relations with the Company;
• if you are a former employee of STROYRENT EOOD, the information was received within the framework of your employment relationship with the Company and the report was submitted after the termination of your employment contract;

Reports submitted by an individual, personally or through a proxy with an express written power of attorney (notarization not required) are considered. When submitting a report by proxy, the original power of attorney is attached to the report.

Pursuant to Art. 9 of Whistleblowers Protection Act, proceedings are not instituted on anonymous reports, as well as on reports relating to breaches committed more than two years ago.

2. In which areas can you report breaches?

You can report the following breaches for which you have received information that they were committed in or are related to STROYRENT EOOD:

2.1. Breaches of the Bulgarian legislation or of the acts of the European Union specified in the annex to Whistleblowers Protection Act in the field of:

• public procurement;
• financial services, products and markets and the prevention of money laundering and terrorist financing;
• product safety and compliance;
• safety of transport;
• environmental protection;
• radiation protection and nuclear safety;
• food and feed safety, animal health and humane treatment;
• public health;
• consumer protection;
• the protection of privacy and personal data;
• the security of networks and information systems.

2.2. Breaches that affect the financial interests of the European Union within the meaning of Art. 325 of the Treaty on the Functioning of the European Union and further specified in the relevant measures of the Union.

2.3. Breaches of the rules of the internal market within the meaning of Art. 26, paragraph 2 of the Treaty on the Functioning of the European Union, including the rules of the European Union and Bulgarian legislation on competition and state aid.

2.4. Breaches related to cross-border tax schemes, the purpose of which is to obtain a tax advantage that is contrary to the object or purpose of the applicable law in the field of corporate taxation.

2.5. Committed publicly prosecuted crimes of which the persons under p.1 have learned in connection with the performance of their work or in the performance of their official duties.

2.6. Breaches of the Bulgarian legislation in the field of:

• the rules for payment of due public state and municipal receivables and
• labor legislation.

Complaints, signals or other plaints about irregularities or dissatisfaction of customers or users of the services provided by STROYRENT EOOD are not considered under the procedure of Whistleblowers Protection Act.

3. How to report a breach?

You can report in the following ways:

• through the Company's internal reporting channel or
• to the Commission for the Protection of Personal Data (CPDP), at the address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2, e-mail: whistleblowing@cpdp.bg, Internet page: www.cpdp.bg.

STROYRENT EOOD encourages reporting signals through the Company's internal reporting channel so that they can be dealt with quickly and efficiently. The Company is committed to ensuring timely and adequate consideration of a report submitted through the internal reporting channel, so that such a choice would not prevent or delay in any way actions to remedy the breach, if such is found.

Reports submitted through the Company's internal reporting channel are considered by employees of STROYRENT EOOD in the "Legal" department (hereinafter referred to as "responsible persons"), who are assigned by order of the manager of STROYRENT EOOD.

Apart from the described ways of reporting, you can publicly disclose the information about a committed breach subject to the conditions for this specified in Whistleblowers Protection Act.

4. How can you use the Company's internal reporting channel?

You can report a breach in or related to the Company by reporting to the responsible persons in one of the following ways:

• By e-mail to the following e-mail address: concerns@stroyrent.bg;
• By post via postal shipment to the address of STROYRENT EOOD: Sofia, 273 Botevgradsko Shosse Blvd., with mandatory addressing to the "Legal" department and marking the shipment "Confidential - to the attention of the responsible persons under Whistleblowers Protection Act";
• By phone call - between 08:30 - 17:30 from Monday to Friday, tel: 0700 1 9988;
• In person - by arranging a personal meeting with one of the responsible persons. The personal meetings are held at the address: Sofia, 273 Botevgradsko Shose Blvd. during the Company's working hours after a date and time previously agreed upon by the parties.

Reports can be made orally (by phone call or in person) or in writing (by email or post). You can submit written reports by filling in a form according to a model approved and publicly available on the CPDP website. You can also submit a written report in a free form, providing at least the following data:

• Your full name, address and phone number, and email address, if you have one;
• the names of the persons against whom you are filing the report and their workplace, if the report is filed against specific individuals and they are known;
• specific details of a breach or of a real danger that a breach will be committed, place and period of the breach, if it was committed, a description of the act or the situation and other circumstances, as far as they are known to you;
• date of submission of the report;
• signature, electronic signature or other identification of you.

You can attach to the report any documents that support your claims, as well as indicate details of persons who could confirm the reported data.

5. What happens after you file a report?

When you submit a report through the Company's internal reporting channel about a breach that falls within the scope of the Whistleblowers Protection Act, within 7 days of receiving the report, we will notify you that the report has been received.

If your report does not comply with the requirements of the law and does not contain the minimum required data specified above, you will be sent a notification to correct the irregularities. If you do not correct the irregularities within 7 days of receiving the notification, your report and its attachments will be returned to you.

If your report contains obviously false or misleading claims, it will be returned to you with an instruction to correct the claims and with information about the criminal liability under Art. 286 of the Penal Code, which you bear for slander.

When your report falls within the scope of Whistleblowers Protection Act and there is no reason for its return, within no later than 3 months from the confirmation of receipt of the report, you will be provided with feedback on the actions taken in connection with the report you submitted. The information is provided regardless of whether the verification has been completed or is still in progress. You may at any time request information from the responsible persons regarding the report you submitted. After compleeting the review of the report, you will receive information about the final results of the review.

For more information:

Report registration form for the submission of information on breaches under the Whistleblower Protection Act