INFORMATION

ON THE PROCEDURE FOR INTERNAL REPORTING OF VIOLATIONS

COMPANY “INCLUSIVE BULGARIA” JSC

under the Law on the Protection of Persons Reporting Violations

or publicly disclosing information about violations (ZPLRPDV)

This information is based on the requirements provided in the Law on the Protection of Persons Reporting Violations or Publicly Disclosing Information about Violations and European legislation (2019/1937 – EU Directive on the protection of persons who report breaches of Union law).

The Law on the Protection of Persons Reporting Violations or Publicly Disclosing Information about Violations (ZPLRPDV) aims to provide protection to persons who report violations or publicly disclose information about breaches of Bulgarian law or acts of the European Union, which they became aware of during or in connection with the performance of their employment or official duties, or in another work context.

Persons entitled to protection under ZPLRPDV

A natural person (whistleblower under Article 5, paragraph 2 of ZPLRPDV) has the possibility to submit a violation report through the internal reporting channel established by “INCLUSIVE BULGARIA” JSC, UIC 207161314, who may be:

• a person who performs work without an employment relationship and/or practices a freelance profession and/or crafts activity, in the context of relations with “INCLUSIVE BULGARIA” JSC, UIC 207161314;
• a volunteer, paid or unpaid intern at “INCLUSIVE BULGARIA” JSC, UIC 207161314;
• a partner, shareholder, sole owner of capital, member of a management or supervisory body of a company, member of the audit committee of an enterprise, which has had or is in the process of establishing relations with “INCLUSIVE BULGARIA” JSC, UIC 207161314;
• a person who works for a natural or legal person, their subcontractors or suppliers, which has relations with “INCLUSIVE BULGARIA” JSC, UIC 207161314;
• a person whose employment or official relationship is about to begin, or a person about to conclude a contract for the provision of any type of service, in cases where the information about violations is obtained during the selection process or other pre-contractual relations with “INCLUSIVE BULGARIA” JSC, UIC 207161314;
• a worker or employee, as well as any other person under Article 5, paragraph 2, points 1 – 5 of ZPLRPDV, who obtained the information within an employment, official, or other work-related relationship, which has ended by the time the report or public disclosure is made.

How to submit a violation report.

1. Orally by phone at +359/884421451 or via a personal meeting with the employee responsible for handling the report at the address: Sofia, “Todor Aleksandrov” Blvd. 71, floor 5, after scheduling an appointment in advance by phone. The report is documented by filling out a standard form.

2. By courier with a shipment to the office of the person responsible for receiving reports at the address: Sofia, “Todor Aleksandrov” Blvd. 71, floor 5, on which the recipient’s address includes the text “Report under ZPLRPDV”. The shipment is immediately handed over to the employee responsible for handling reports at “INCLUSIVE BULGARIA” JSC, UIC 207161314;

3. By email, at the address: Complete the standard form and send it to the following email: [email protected];

* Written reports are signed by the persons submitting them. When submitted electronically, the form is signed with a qualified electronic signature.

The written report is submitted by the sender through filling out the standard form. Oral reports are documented by the employee responsible for handling reports, who offers the whistleblower the opportunity to review, correct, and approve it by signing. With the explicit consent of the whistleblower, an oral report submitted via telephone or another voice messaging system, or in a personal meeting, may also be documented using a permanent recording medium allowing its retrieval.

* You may attach any type of information sources supporting your statements and/or reference documents, including identifying persons who could confirm the reported information or provide additional details.

! All fields in the form must be completed.

If the report does not meet any of the requirements, the responsible person notifies the submitter to correct the irregularities within 7 days. If the irregularities are not corrected within this period, the report along with attached documents is returned to the submitter.

The employee responsible for the report provides feedback on the actions taken within no more than 3 months after confirming receipt of the report.

The identity of the whistleblower and any other person mentioned in the report will be duly protected, and necessary measures will be taken to limit access to the report by unauthorized persons.

! No procedure is initiated for anonymous reports.

The form can be downloaded HERE. For more information or questions, you can contact the External Officer for submitting reports:

“Collect Services Group” Ltd., UIC 20321089, with registered office at: Sofia, Ovcha Kupel residential area, 2 “Naroden Hero” St., building “A”, ground floor, apt. 1, tel. +359 877410790 and email: [email protected]