The procedure for internal reports

PROCEDURE FOR ACCEPTANCE OF REPORTS.

(1) Any Submitter who has knowledge or reasonable suspicion that an Infringement has occurred shall have the opportunity to make a report of such Infringement under the terms of these Rules.

 (2) A Submitter shall be protected provided that the Submitter had reasonable grounds to believe that the Infringement Information that is the subject of the Submission or Public Disclosure is true at the time the Submission or Public Disclosure is made and that such information constitutes Infringement Information.

[Form of Making Notifications]

(3) Notification may be made through:

(a) an internal Notification channel, i.e., a dedicated IT system provided by the Company for this purpose (the "Whistleblowing System") that provides optimal technical and organizational solutions to ensure compliance of the Regulations with the provisions of the Directive

b) e-mail address (compliancePFLEAST-helpdesk@pfleiderer.pl), handled by the Legal and Compliance Department,

c) contact number, serviced by the Compliance Manager on business days from 9:00 a.m. to 5:00 p.m;

d) a personal meeting with the Compliance Manager on business days from 9:00 a.m. - 5:00 p.m; 

(4) Notification may be made by the Notifier:

(a) with personal data enabling him/her to be identified and contacted, including in particular his/her name and contact address or telephone number (open notification), or

b) without providing personal data enabling him/her to be identified and contacted (anonymous submission).

(5) The application should, to the extent possible for the Applicant, contain all the information that is required in the form made available by the Company through the dedicated information system.

[Receipt of Notifications]

(6) The Compliance Manager shall be the competent entity to receive notifications, with written authorization from the Employer and Pfleiderer Group companies. 

(7) If personal and/or contact information is provided by the Submitter, the Compliance Manager and the Compliance Committee Members shall keep it confidential and treat the submission as anonymous to third parties.

[Acknowledgement of Receipt of Notification]

Whenever possible, within 7 (seven) days from the date of receipt of the Submission, the Compliance Manager shall confirm receipt of the Submission to the Submitter. At the same time, the Submitter shall be advised of the expected timeframe for handling the matter. Confirmation of receipt of the notification may be automated.

[Violation relating to the authority designated to process Submissions].

(8) If the Notification concerns the Compliance Manager, the relevant actions provided for in these Regulations shall be performed in place of the Compliance Manager by a person designated by the Compliance Committee. If the Notification relates to a member of the Compliance Committee, the actions relating to the respective Notification shall be performed by the Compliance Committee to the exclusion of that member.