Whistleblowers Protection Act

Signals under the Act on Protection of Persons, Reporting Information, or Publicly Disclosing Information about Breaches (Whistleblowers Protection Act), can be submitted to Resolute Software, UIC: 205596894, through an internal reporting channel:

• At the telephone number 028685278, during the company's working hours (from 08:00 to 17:00, every weekday).
• To the e-mail address whistleblowing@resolutesoftware.com;
• On-site at the company's Head Office to the employee designated to review signals: Bulgaria, Sofia, 141 Tsarigradsko shose Bld.

No proceedings shall be initiated on anonymous signals.

For filing signals or publicly disclosing false information, a fine on the relevant person could be imposed and the affected person has the right to claim compensation.

More information can be found in the following sections.

A natural person could file a report or disclose public information on matters concerning:

1. Breaches of Bulgarian legislation or of the acts of the European Union in the field of:
   
   1. Public procurement;
   2. Financial services, products and markets and the prevention of money laundering and terrorist funding;
   3. Product safety and compliance;
   4. Transport safety;
   5. Environmental protection;
   6. Radiation protection and nuclear safety;
   7. Foods and fodder safety, animal health and welfare;
   8. Public health;
   9. Consumer protection;
   10. Protection of privacy of personal life and personal data;
   11. The security of networks and information systems;
2. Breaches that affect the financial interests of the European Union;
3. Breaches of the rules of the internal market including the rules of the European Union and Bulgarian legislation on competition and state aid;
4. Breaches related to cross-border tax schemes, the purpose of which is to obtain tax advantage, that is contrary to the subject or purpose of applicable law in the field of corporate taxation;
5. Committed crime of a general nature, about which the whistleblower has learned in connection with the performance of his work or in the performance of his official duties.
6. The rules for payment of due public state and municipal receivables;
7. Labour legislation;
8. The legislation related to the performance of civil service.

A whistleblower is a natural person who files a report or publicly discloses information about a violation that has become known to him/her in his/her capacity as:

1. Worker, employee, civil servant or other person who performs wage labour, regardless of the nature of the work, the method of payment and the source of financing;
2. A person with self-employed status including a person who works without an employment relationship and/or exercises a freelance profession and/or a craft;
3. A volunteer, paid or unpaid, and an intern;
4. A partner, shareholder, sole owner of the capital, member of the management or control body of a commercial company, member of the audit committee of an enterprise;
5. A person who works for a natural or legal person, contractors, his subcontractors or suppliers;
6. A person whose employment or service relationship is about to begin in cases where the information about the violations was received during the selection process or during other pre-contractual relations;
7. A worker or employee, when the information was obtained within the framework of an employment or service relationship that was terminated at the time of filing the report or the public disclosure.

Protection is provided to a reporting person from the moment of filing the report or public disclosure of information on a violation.

A person filing a report on violations through an internal or external channel has the right to protection, provided that:

1. Has had a reasonable reason to believe that the provided information about the breaches in the report was correct at the time of its submission and that this information falls within the scope mentioned above;
2. Has reported a breach under the terms and conditions of Whistleblowers Protection Act.

A person who publicly discloses information about a violation is entitled to protection under the law when he had reasonable grounds to believe that the information about the violation was correct at the time of its disclosure and that this information falls within the scope above, and one of the following conditions is met:

1. The person has filed a report under the terms and conditions of the law, but no relevant actions have been taken on the report within the time limits provided for in the law;
2. The person has grounds to believe that:
   1. The violation may constitute an immediate or clear danger to the public interest or there is a risk of damage that cannot be eliminated;
   2. In the case of external reporting, there is a risk of retaliation or there is a possibility that the violation will not be effectively addressed due to the risk of concealment or destruction of evidence, suspicion of collusion between the competent authority and the perpetrator of the violation, or complicity of the authority in the violation, as well as due to other specific circumstances of the case.

According to the law, the report should be submitted as a priority through an internal reporting channel. In case there is a reasonable assumption that the reporting person is at risk of retaliation, discrimination, and that effective measures will not be taken to verify the report, the report may be submitted through an external reporting channel to the Commission for personal data protection.

Persons reporting or publicly disclosing information about violations may choose the method of reporting, as one or a combination of methods.

Internal reporting

The report shall be submitted to the employee responsible for reviewing reports, in writing or orally. The oral reporting may be carried out by telephone, and at the request of the reporting person – through a personal meeting within a suitable period agreed upon between the parties.

The written report shall be submitted by the sender by filling out specified form or in plain language. The oral report shall be documented by filling out a form by the employee responsible for reviewing reports, who shall offer the reporting person to sign it.

Any source of information supporting the allegations made therein and/or reference to documents may be attached to the report, including the details of persons who could confirm the reported data or provide additional information.

If the report does not meet the requirements, the reporting person shall be sent contacted in order to eliminate the irregularities within 7 days of receiving the report. If the irregularities are not eliminated within this period, the report together with the attachments shall be returned to the reporting person.

Each report shall be checked for its credibility. Reports that do not fall within the scope of the said law and whose content does not give grounds to consider them credible shall not be considered. Reports that contain obviously false or misleading statements of fact shall be returned with an instruction to the sender to correct the statements and to assume the responsibility for the report.

Feedback to the sender of the signal on the actions taken shall be provided within three months of the confirmation of receipt of the signal, which shall be made within 7 days of receipt.

Inspections shall be terminated on a repeated signal that does not contain new information of material importance for a violation in respect of which an inspection has already been completed, unless new legal or factual circumstances give grounds for taking further action.