Internal Reporting Procedure (Whistleblowing)

Chapter III. Whistleblower

1. A whistleblower is a natural person who reports or publicly discloses information about a violation of the law obtained in a work-related context, as defined in detail in point 17 of § 6 of the Procedure.
2. A whistleblower is entitled to the protection specified in generally applicable laws in this regard from the moment the report is made or the information is publicly disclosed, provided that the whistleblower had reasonable grounds to believe that the information subject to the report or public disclosure was true at the time of the report or public disclosure and that it constituted information regarding a violation of the law.
3. A whistleblower is subject to criminal liability as defined in generally applicable laws in this regard if they file a report or make a public disclosure knowing that no violation of the law has occurred.

Chapter IV. Rules for Making Internal Reports

1. The person authorized to receive internal reports and take follow-up actions is the Accounting and Administration Director, and in his or her absence, the Sales, Marketing & Business Development Director.
2. If the content of the report indicates that the person authorized to receive internal reports and take follow-up actions may be in any way—directly or indirectly — involved in the act or omission that is the subject of the report, they may not take any action related to that report. In such a situation, the whistleblower shall submit the report to the other person indicated in paragraph 1 above.
3. In special cases, PMR LTD. Sp. z o.o. may temporarily authorize another person or persons to receive internal reports and take follow-up actions, while respecting the principle of impartiality.
4. Persons authorized to receive internal reports and take follow-up actions are required to protect the personal data of the whistleblower and other individuals whose personal data is processed in connection with the report and the follow-up actions taken, and to maintain confidentiality regarding all activities related to the internal reports received, even after the termination of the employment relationship or other legal relationship under which they performed these activities.
5. The person authorized to receive internal reports and take follow-up actions conducts an initial review of the report, maintains further communication with the whistleblower—including requesting additional information—and provides feedback to the whistleblower.
6. PMR LTD. Sp. z o.o. and any other person shall not have the right to influence the performance of duties by the person authorized to receive internal reports and take follow-up actions, issue instructions to that person, or influence the manner in which they perform their work.
7. The person authorized to receive internal reports and take follow-up actions is required to perform the activities set forth in this procedure conscientiously and diligently, exercising due care.
8. The person authorized to receive internal reports and take follow-up actions is required to provide the whistleblower and the person subject to the report with information regarding the processing of personal data, in accordance with generally applicable regulations in this regard. A template of this information is also published on the PMR LTD. Sp. z o.o. website.

1. Subject to paragraph 3, this Procedure does not provide for the acceptance of anonymous reports.
2. If an anonymous report is received, it shall not be investigated.
3. The person authorized to receive reports and take follow-up actions may decide to review an anonymous report if the content of the report raises significant issues related to a violation of the law that are subject to reporting under this procedure.

1. At PMR LTD. Sp. z o.o., the following procedure is established for whistleblowers to submit internal reports verbally via an unrecorded telephone line at the following number:

• Accounting and Administration Director – +48 609 636 042 or, in the event of his absence:
• (Sales, Marketing & Business Development Director) – +48 609 400 505
  , i.e., numbers staffed by persons authorized to receive internal reports, from which a record of the whistleblower’s internal report of a legal violation is immediately prepared, recording its exact course of events, in accordance with the template set forth in Appendix No. 2 to the Procedure.

  2. If the report concerns members of the legal entity’s management board, the whistleblower shall submit the report in writing to the legal entity’s address with the following note on the envelope: “Whistleblower – to be delivered personally to the shareholders.” In the event that a member of the management board is also a partner of the legal entity, the note on the envelope should refer to the other partners, with the exception of the one to whom the report pertains. In the situation described in this paragraph, the partners of the legal entity are the persons authorized to receive reports and take follow-up actions. The provisions of the procedure apply accordingly in this case.

  3. The report should contain a clear and complete explanation of the subject matter of the report and should include at least the following information: the date and place where the legal violation occurred or the date and place where information about the legal violation was obtained, a description of the specific situation or circumstances giving rise to the possibility of potential witnesses to the violation of the law, an indication of all evidence and information available to the Whistleblower that may prove helpful in the process of reviewing the report, and an indication of the preferred method of contact.

  4. A report may be filed only in good faith. Knowingly filing false reports is prohibited. A person who files a report knowing that no violation of the law has occurred (a report made in bad faith) is subject to a fine, a restriction of liberty, or imprisonment for up to 2 years.

  5. If it is determined that the report knowingly contained false information or concealed the truth, the person making the report may be held liable under the disciplinary provisions of the Labor Code. Such conduct may also be classified as a serious violation of the fundamental obligations of employees or persons performing paid work on a basis other than an employment relationship and, as a consequence, may result in the termination of the employment contract or civil law contract without notice.

The person authorized to receive internal reports is required to confirm receipt of the report to the whistleblower within 7 days of receipt, unless the whistleblower has not provided a contact address to which the confirmation should be sent.

1. The whistleblower shall receive feedback within a period not exceeding 3 months from the confirmation of receipt of the report or, if no confirmation was sent to the whistleblower, 3 months from the expiration of the 7-day period following the submission of the report, unless the whistleblower has not provided a contact address to which the feedback should be sent.
2. The person authorized to receive internal reports is required to provide feedback to the whistleblower by:
   a) sending a letter to the contact address indicated in the report acknowledging receipt of the whistleblower’s internal report of a legal violation, in which a sealed additional envelope marked “whistleblower” containing the feedback, or
   b) personally delivering written feedback to the whistleblower, which the whistleblower confirms on a copy of that document.

1. The person authorized to receive internal reports shall maintain a register of internal reports in accordance with the template set forth in Appendix 1 to this procedure.
2. The following data shall be recorded in the internal report register:

• report number;
• subject matter of the legal violation;
• personal information about the whistleblower and the person to whom the report relates, necessary to identify these individuals;
• the whistleblower’s contact address;
• the date the report was filed;
• information on the follow-up actions taken;
• the date the case was closed.

3. Personal data and other information in the internal report registry are retained for a period of 3 years following the end of the calendar year in which the follow-up actions were completed, or following the conclusion of any proceedings initiated as a result of those actions.

Chapter V. Follow-up Actions

1. A person authorized by PMR LTD. Sp. z o.o. to receive internal reports and take follow-up actions shall, upon receipt of a report, begin drafting a report on the review of the whistleblower’s report of a legal violation in accordance with the template set forth in Appendix No. 3 to this procedure.
2. The person authorized to take follow-up actions shall conduct a preliminary review of the report and take appropriate follow-up actions.
3. If the person authorized to take follow-up actions is unable to carry out the necessary follow-up actions independently, they shall consult with the person representing PMR LTD. Sp. z o.o. to determine the necessary scope of those actions.
4. The representative of PMR LTD. Sp. z o.o., together with the person authorized to take follow-up actions, may decide to appoint a Team to investigate the internal report.
5. External specialists may be appointed to the Team.
6. If there are no competent employees available to investigate the internal report, the representative of PMR LTD. Sp. z o.o. may appoint only an external specialist or a team of external specialists.
7. The person authorized to take follow-up actions or the Team appointed to investigate the internal report shall act impartially and completely independently, exercising due diligence and conscientiousness in their actions.
8. The person authorized to take follow-up actions or the team appointed to investigate the internal report has the right to access all data necessary to investigate the internal report, based on the authorization granted in this regard.
9. All employees and other individuals collaborating with PMR LTD. Sp. z o.o. are required to cooperate with the person authorized or the team designated to follow up on the internal report in order to investigate it.
10. The person authorized to take follow-up actions or the Team appointed to investigate the internal report is required to investigate the matter and prepare a report on the work conducted, in accordance with the template specified in Appendix No. 3 to this procedure, containing conclusions, recommendations, follow-up actions, and the rationale for those actions.
11. The report must be prepared in a timely manner to ensure that the whistleblower receives feedback promptly.
12. After the report is prepared, the internal entity authorized to receive internal reports provides feedback to the whistleblower.
13. The feedback shall include, in particular, information regarding planned or taken follow-up actions and recommendations aimed at eliminating and preventing violations identical or similar to those described in the report, as well as the reasons for such actions.
14. The person authorized to take follow-up actions may decide to refrain from verifying the Report if the report is clearly false or if it is impossible to obtain from the Whistleblower the additional information necessary to verify the report.

Chapter VI. Prohibition of Retaliatory Actions

1. There is an absolute prohibition on taking retaliatory actions or threatening such actions against a whistleblower who has filed a report (including an external report as referred to in Chapter VII), as well as against any person assisting the whistleblower in making the report and any person associated with the whistleblower.
2. Any repressive, discriminatory, or otherwise unfair treatment of a whistleblower shall be considered a violation of the Procedure and may result in disciplinary action or the termination of the contract between the person taking retaliatory action and the legal entity.
3. Retaliatory actions against a whistleblower, a person assisting in making the report, or a person associated with the whistleblower are punishable by a fine, restriction of liberty, or imprisonment for up to 2 years, and if the perpetrator acts persistently, is punishable by imprisonment for up to 3 years.

Chapter VII. Procedure for Making External Reports

1. A reporter may file an external report without first filing an internal report.
2. An external report is accepted by the Ombudsman or a public authority.

1. An external complaint may be filed orally or in writing.
2. An external complaint in written form may be submitted:

• in paper form—to the mailing address specified by the Ombudsman or the public authority accepting the complaint;
• in electronic form—to the email address, electronic drop box address, or electronic service address specified by the Ombudsman or the public authority receiving the complaint; or via a designated online form or application identified by the public authority as the appropriate application for submitting reports electronically.

Public authorities and the Ombudsman shall post information for whistleblowers on their websites in the Public Information Bulletin in a separate, easily identifiable, and accessible section.

The Ombudsman or the public authority that received the external report shall immediately, but no later than within 7 days from the date of receipt of the report, send the whistleblower a confirmation of receipt, unless the whistleblower has expressly requested otherwise or the Ombudsman or the public authority has reasonable grounds to believe that confirming receipt of the report would jeopardize the confidentiality of the whistleblower’s identity.

An external report may also be submitted to the relevant bodies and organizational units of the European Union, such as the European Anti-Fraud Office (OLAF), the European Maritime Safety Agency (EMSA), the European Aviation Safety Agency (EASA), the European Securities and Markets Authority (ESMA), and the European Medicines Agency (EMA), which have external reporting channels and procedures in place for receiving reports, primarily ensuring the confidentiality of the identity of those making the reports.

Chapter VII. Final Provisions

1. The internal reporting procedure is published in an easily accessible location on the PMR LTD. Sp. z o.o. and on the PMR LTD. Sp. z o.o. website, available at: https://pmrmarketexperts.com.
2. In matters not covered by this internal reporting procedure, the generally applicable provisions regarding the protection of whistleblowers shall apply accordingly.
3. Amendments to this internal reporting procedure shall be made in the same manner as its creation.