Whistleblowers - Code of Conduct
1. The Whistleblower Protection Policy outlines the detailed rules and procedures for whistleblowers to report legal violations, as well as the principles for receiving and handling such reports.
2. Receiving reports of legal violations is an essential component of the proper and safe functioning of the Company. It helps improve the efficiency of identifying irregularities and taking actions to eliminate and mitigate risks at all organizational levels.
3. Reports can be made through the following communication channels:
a) via email at: sygnalisci@spoc.eu
b) in writing, addressed to the Legal Department at Szyperska 14, 61-754 Poznań
4. The Company ensures the confidentiality of the information provided in the report and guarantees that the whistleblower’s identity will not be disclosed to anyone other than those authorized to analyze the received reports, except in cases outlined in points 5 and 6 of this Policy.
5. The person submitting the report may consent to the disclosure of their identity or other information that could directly or indirectly identify them.
6. If the person submitting the report has not consented to the disclosure of their identity, the whistleblower’s identity and any other information related to the report may only be disclosed if it is necessary under legal regulations, including for purposes of investigations or legal proceedings conducted by designated state authorities. The whistleblower will be informed of such disclosure prior to it being made, unless such notification could compromise the related investigation or legal proceedings.
7. The report should be made with due care and diligence. The whistleblower is protected provided they had reasonable grounds to believe that the information reported regarding the legal violation was true at the time of the report. The report should include:
a) a clear and complete explanation of the subject of the report or legal violation,
b) the date and place of the legal violation or the date and place the information about the violation was obtained,
c) a description of the situation or circumstances that could lead to the legal violation,
d) an indication of the entity to which the report pertains,
e) identification of witnesses to the violation,
f) provision or attachment of evidence and information that may be helpful in analyzing the report,
g) indication of the preferred method of contact for feedback,
h) consent/lack of consent to the disclosure of identity.
8. The responsible person or team will acknowledge receipt of the report within 7 days of its submission, unless the whistleblower did not provide a possible method for feedback or submitted the report anonymously.
9. The investigation begins upon receipt of the report, i.e., when the email is read or when the report reaches the office located at Szyperska 14, 61-754 Poznań. The investigation is conducted by the responsible person or team. The whistleblower is not a party to the investigation.
10. The responsible person or team will promptly provide the whistleblower with information about the outcome of the investigation and any subsequent actions taken as a result of the report, no later than 3 months from the date of acknowledgment of receipt of the report or 3 months from the expiration of 7 days from the receipt of the report in the event no acknowledgment was provided.
11. A legal violation is any action or omission that is contrary to the law or aimed at circumventing the law.
12. The information reported by the whistleblower pertains to:
a) corruption;
b) public procurement;
c) financial services, products, and markets;
d) prevention of money laundering and terrorism financing;
e) product safety and compliance with requirements;
f) transport safety;
g) environmental protection;
h) radiological protection and nuclear safety;
i) food and feed safety;
j) animal health and welfare;
k) public health;
l) consumer protection;
m) privacy and personal data protection;
n) network and information systems security;
o) financial interests of the State Treasury of the Republic of Poland, local government units, and the European Union;
p) the EU internal market, including public competition law and state aid, and corporate taxation;
r) constitutional freedoms and human and civil rights in relations with public authorities, unrelated to the areas mentioned above.
13. The report may concern a reasonable suspicion of an actual or potential legal violation that has occurred or is likely to occur at the Employer.
14. A whistleblower who provides false information or conceals the truth in their report may be held liable under the Labor Code, with such behavior potentially being classified as a serious breach of basic employee duties, leading to termination of employment without notice.
15. For individuals providing services or goods based on a civil contract, submitting a false report may result in the termination of the contract and cessation of cooperation.
16. Reports must be made in good faith. It is prohibited to knowingly submit false reports. Under the provisions of the Act of June 14, 2024, on Whistleblower Protection, a person submitting false information may be subject to a fine, restriction of liberty, or imprisonment for up to 2 years.
