Internal reporting procedure

Internal Reporting Procedure at Commercecon Sp. z o.o., Sp. k. in relation to the Act of 14 June 2024 on the protection of whistleblowers

Pursuant to the provisions of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of whistleblowers and pursuant to Article 25 of the Law on the Protection of Whistleblowers of 14 June 2024 Coll. 2024 item 928 (hereinafter the “Act”) , Commercecon Sp. z o.o. Sp. k. establishes the following procedure for internal notifications:

1. Persons authorised to receive internal reports (hereinafter: Recipient of the report), within the organisational structure of Commercecon Sp. z o.o. Sp. k., are employees of the human resources department of Commercecon Sp. z o.o. Sp.k.
2. The persons authorised to verify the reports and follow up, within the organisational structure of Commercecon Ltd. Sp. k., are employees of the legal department of Commercecon Sp. z o.o. Sp. k. (hereinafter: follow-up team).The persons authorised to verify the reports and follow up, within the organisational structure of Commercecon Ltd. Sp. k., are employees of the legal department of Commercecon Sp. z o.o. Sp. k. (hereinafter: follow-up team).
3. Methods of internal reports made by the Whistleblower with or without giving a contact address or without it :
   a) The Whistleblower may make a report orally (by telephone at 42 6321020) or by means of electronic communication within the meaning of Article 2(5) of the Act of 18 July 2002 on provision of services by electronic means) – each report made in this form is documented by a record containing the exact course of the conversation.
   b) At the request of the Whistleblower, an oral report may be made during a face-to-face meeting organised within 14 days of receipt of such a request. In such a case, with the consent of the Whistleblower, the report shall be documented in the form of: a recording of the interview allowing the Whistleblower to listen to it or a record of the meeting describing the interview in detail.
   c) The Whistleblower may verify the correctness and approve the record of the interview by signing it.
   d)The Whistleblower may make a written report in paper form, via snail mail to the following address: Commercecon Sp. z o.o. Sp. k. ul. Inwestycyjna 5, 95 – 050 Konstantynów Łódzki (subject to point 4) below) or electronically at the e-mail address ( [email protected] ).
4. Commercecon Sp. z o.o. Sp. k. will not make any attempt to establish the identity of the Whistleblower who has chosen to remain anonymous, and any action in this regard, constitutes an Infringement. In order to preserve full anonymity, reports sent by post should be sent in a sealed envelope marked “CONFIDENTIAL – WHISTLEBLOWER” placed in a further envelope marked “reporting violations – infringements”. The report is handed directly to the Recipient. Such correspondence is not subject to registration under Commercecon Sp. z o.o.’s general rules. Sp. k. The Recipient is obliged to keep the Whistleblower’s details confidential, in accordance with the Whistleblower’s wishes.
5. The Whistleblower who has provided a method and address for contact will receive an acknowledgement from the recipient of the internal report within 7 days of receipt.
6. The follow-up team, upon receipt of an internal report and its verification, will follow up by initiating an investigation, initiating a control procedure, taking action against the breach, taking corrective action and closing the procedure. The follow-up team maintains a record of internal reports.
7. The Whistleblower who has provided a contact address will receive feedback from the follow-up team within 3 months of the acknowledgement of the internal report.
8. In addition to and independently of internal reporting, the Whistleblower may make external reports to the Ombudsman(https://bip.brpo.gov.pl/pl) or public authorities and, as appropriate, to the institutions, bodies, offices or agencies of the European Union. The details for making external notifications are set out in Chapter 4 of the Act.
9. The annexes to the internal reporting procedure are:

a) the internal report form, (in polish),

b) GDPR information clause (in Polish),

c) Act on the protection of whistleblowers of 14 June 2024 Coll. 2024 item 928 (in polish),,

d) template for the Whistleblower’s internal reporting call record (in polish) ,

e) the record of internal reports template (in polish).

10. The procedure will be made available on the company intranet under the tab – Internal
11. The procedure enters into force 7 days after being communicated.