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​FENEGA WHISTLEBLOWING POLICY​

​​The conditions for providing protection to individuals in an employment relationship in connection with reporting criminal activity or other forms of anti-social conduct (hereinafter referred to as “anti-social conduct”), as well as the rights and obligations of individuals when reporting such conduct, are governed by Act No. 54/2019 Coll. on the Protection of Whistleblowers of Anti-Social Conduct and on Amendments to Certain Acts (hereinafter referred to as the “Whistleblower Protection Act”).

FENEGA, s.r.o. (hereinafter referred to as “the company”) has issued, pursuant to Section 10(9) of the Whistleblower Protection Act, an internal regulation that sets out the procedure for submitting and reviewing reports of anti-social conduct, as well as the conditions for providing protection to whistleblowers.

Any natural person in an employment relationship with the company, or in another comparable working relationship, as well as a close person to such an individual or an anonymous reporter, may, in accordance with the internal directive, submit to the company a notification regarding facts learned in connection with the performance of their employment, profession, position, function, or other activity, which relate to anti-social conduct. Such notification may be submitted through the designated responsible person.
 
​​The duties of the designated responsible person under the Whistleblower Protection Act are fulfilled, on behalf of the company, by the accountant, who maintains the record of submitted reports.

Anti-social conduct shall be understood as:
• ​criminal activity, i.e., conduct that constitutes a criminal offence,
• ​other forms of anti-social conduct, i.e., behaviour that constitutes an offence or another administrative delict, as well as behaviour that does not constitute an offence or administrative delict but has a negative impact on society, such as illegitimate, unethical, or unlawful practices in the workplace.

A report of anti-social conduct may be submitted to the company, in accordance with the internal directive, through the following means:

·  ​in written form directly to the designated responsible person:
FENEGA, s.r.o..,
„K rukám zodpovednej osoby “
Alžbeta Vereščáková
Kračúnovce 51, 087 01 Kračúnovce

· 
in written form to the authorised person at the company’s address:  
„K rukám zodpovednej osoby “
Alžbeta Vereščáková
Kračúnovce 51, 087 01 Kračúnovce

· ​orally, recorded in the office of the authorised person,

• ​by e-mail to verescakova@fenega.sk, which is accessible at all times, including for anonymous submissions.

A report of anti-social conduct may also be submitted through external systems such as:

·  ​the Prosecutor’s Office,
·  ​​administrative authorities,
·  ​the Office for the Protection of Whistleblowers,
·  the relevant institutions of the Union. 

​The detailed procedure followed by the company when handling reports of anti-social conduct, as well as the measures for protecting whistleblowers, is governed by the company’s internal directive.

FENEGA WHISTLEBLOWING POLICY