INFORMATION ON THE PROCEDURE AND CONDITIONS FOR

INTERNAL REPORTING OF VIOLATIONS

IN “TEHRA” LTD

“TEHRA” LTD (the Company) is a private entity obligated under the Protection of Persons who Report or Publicly Disclose Information about Infringements Act (PPDPILA/the Act), which is why the company has established an internal channel for reporting violations of Bulgarian and European legislation in certain areas, which ensures, on the one hand, keeping the identity of the whistleblower confidential, and on the other hand, its effective investigation in order to limit and stop existing and potential violations.

WHERE ARE PPDPILA REPORTS SUBMITTED?

If you have reasonable grounds to believe that a violation has occurred or there is a risk of such occurring within the Company, you can submit a report to the person responsible for reviewing reports at “TEHRA” LTD.

No proceedings are initiated to review anonymous reports, nor reports that relate to violations committed more than two years ago.

Through the internal channel for submitting reports at “TEHRA” LTD, you can submit a report in one of the following ways:

• Written report of violation through:

• filling out a Standard Form from the Personal Data Protection Commission (PDPC)

or

• through a message in free text,

sent in one of the following ways:

• to the email address for submitting reports: signal@com.
• via postal operator as a package, on which under the recipient’s address is written “PPDPILA report“, to the address: Sofia, postal code 1408, Triaditsa district, Ivan Vazov residential complex, 1 Burel Street, to the Employee responsible for reviewing reports.

The package is immediately handed over to the responsible person without being opened.

• in the designated mailbox located on the Company’s premises, specifically in the building of “TEHRA” LTD at 1 Burel Street in Sofia, ground floor.

Regardless of whether you use the form or the report is in free text, the information you provide should contain:

• Full name, address, and phone number of the sender, as well as email address, if any.
• The names of the person against whom the report is being filed, and their workplace, if the report is being filed against specific individuals and they are known.
• Specific data about a violation or a real danger of such being committed.
• Place and period of the violation, if such has been committed.
• Description of the act or situation and other circumstances, as far as such are known to the reporting person.
• Date of submission of the report.
• Handwritten signature, including qualified electronic signature.

In case the report does not meet any of the requirements, the responsible person will send you a message to correct the irregularities within 7 days of receiving the report.

If the irregularities are not corrected within this period, your report will not be considered.

You may attach to the report any kind of information sources supporting your statements and/or references to documents, including indicating data of persons who could confirm the reported data or provide additional information. Providing additional information is not mandatory.

Within 7 days, the receipt of your report will be confirmed in writing.

• Verbal report through a personal meeting with the responsible person at the Company’s address after a pre-arranged meeting at the email address mentioned above.

WHO CAN SUBMIT A REPORT OF VIOLATIONS AND

BENEFIT FROM THE PROTECTION UNDER THE LAW?

Any employee of “TEHRA” LTD, as well as:

• other persons who perform paid work, regardless of the nature of the work, the method of payment, and the source of funding;
• persons who work without an employment relationship and/or practice a free profession and/or craft activity for the benefit or on behalf of the Company;
• volunteers or interns;
• persons who work for a subcontractor or supplier of the Company;
• job applicants who participated in a competition or other form of selection for employment and received information about a violation in this capacity;
• employees of the Company when the information was obtained within the framework of an employment relationship with the Company, which has been terminated at the time of submitting the report or public disclosure.
• any other reporting person who submits a report of a violation that became known to them in a work-related context.
• persons who assist the reporting person in the process of submitting a report;
• persons who are related to the reporting person and who may be subjected to retaliatory actions due to the reporting;
• legal entities in which the reporting person owns a share, for which they work, or with which they are connected in another way in a work context.

WHAT VIOLATIONS CAN BE REPORTED?

The areas for which you can submit a report of violations are:

1. Violations of Bulgarian legislation or the European Union acts listed in Annex I to the Act in the field of:

a) public procurement;

b) financial services, products and markets, and prevention of money laundering and terrorist financing;

c) product safety and compliance;

d) transport safety;

e) environmental protection;

f) radiation protection and nuclear safety;

g) food and feed safety, animal health and welfare;

h) public health;

i) consumer protection;

j) protection of privacy and personal data;

k) security of network and information systems;

l) rules for payment of due public state and municipal receivables;

m) labor legislation;

n) legislation related to civil service performance.

2. Violations of the rules of the internal market in the European Union regarding the free movement of goods, people, services and capital;
3. Violations related to cross-border tax schemes aimed at obtaining a tax advantage that contradicts the subject or purpose of applicable corporate tax law;
4. A committed crime of general nature, which a person – the submitter of the report, has learned about in connection with their work or in the performance of their official duties;

WHAT REPORTS ARE NOT CONSIDERED?

• Anonymous reports;
• Reports of violations committed more than 2 years before the date of submitting the report;
• Reports that are clearly unfounded, clearly trivial, or contain obviously false statements;
• Reports for which there is already a completed procedure in this order and for which no new evidence has been presented.

WHAT RIGHTS AND PROTECTION

DO YOU HAVE AS A WHISTLEBLOWER, AS WELL AS PERSONS RELATED TO YOU?

1. Prohibition of any form of retaliatory actions in connection with the submitted report, having the character of reprisal and placing the whistleblowers in an unfavorable position, as well as threats or attempts at such actions, including in the form of:

a) temporary removal, dismissal or application of another basis for termination of the relationship under which a person performs paid work;

b) demotion or delay in promotion;

c) change in the place or nature of work, duration of working hours or reduction of remuneration;

d) refusal to provide training for maintaining and improving the professional qualification of the worker or employee;

e) negative work evaluation, including in a job recommendation;

f) application of property and/or disciplinary liability, including imposing disciplinary penalties;

g) coercion, rejection, threats of retaliatory actions or actions expressed physically, verbally or otherwise, which aim to harm the dignity of the person and create a hostile professional environment;

h) direct or indirect discrimination, unequal or unfavorable treatment;

i) deprivation of the opportunity to transition from a fixed-term employment contract to an indefinite employment contract, when the worker or employee had a legal right to be offered permanent work;

j) early termination of a fixed-term employment contract or refusal to renew when such is permissible by law;

k) damage, including to the person’s reputation, especially on social networks, or financial losses, including loss of business and loss of income;

l) inclusion in a list, prepared on the basis of an official or unofficial agreement, in a sector or industry, which may lead to the person being unable to find employment or unable to deliver goods or services in that sector or industry (blacklist);

m) early termination or cancellation of a contract for the supply of goods or services, when the person is a supplier;

n) termination of a license or permit;

o) directing the person to undergo a medical examination.

2. Right to keep your identity confidential. Only employees authorized to receive and review reports will have access to your identity data;
3. Right to information regarding the progress and result of the investigation of their submitted report within the statutory deadlines. Within 7 days of submitting the report, the employee responsible for processing it is obliged to provide you with a Unique Identification Number. Within 3 months of submitting the report, the same employee should inform you of the result of the report. During its processing, they may contact you to correct irregularities in the report, provide additional data and evidence;
4. Right to submit a report orally or in writing;
5. Right to refuse to sign a form for registering reports;
6. Right to refuse to have your identity disclosed, if this is necessary for the purposes of investigating the report by the competent authorities;
7. Right to publicly disclose information about violations that have become known to you in a work context;
8. Right to submit your report to the PDPC or another competent authority in the relevant area.

ATTENTION!

You can enjoy the above rights, provided that:

1. there was reasonable cause to believe that the information about the violation submitted in the report was true at the time of its submission and that this information falls within the scope of the Act mentioned above

and

2. you have submitted a report of violation under the conditions and procedure of the Act.

DO YOU BEAR RESPONSIBILITY FOR THE REPORTS YOU SUBMIT?

If you exercise your rights in bad faith and knowingly submit a false report containing non-existent facts and circumstances, you bear civil liability for the damages caused to the person against whom the report is directed. In this case, you are also subject to an administrative penalty – a fine ranging from 3,000 to 7,000 BGN.

If your report contains data about a committed crime that you know to be false, in addition to the above-mentioned liability, you also bear criminal responsibility for false accusation under Article 286 of the Criminal Code.

If you obstruct the investigation of a report submitted by another person or do not provide due assistance to the employee reviewing the report, you may be punished with a fine from 400 to 4,000 BGN for obstructing or attempting to obstruct the submission of a report filed in fulfillment of the purpose of PPDPILA.