INFORMATION ON THE CONDITIONS AND PROCEDURE FOR INTERNAL REPORTING

This information is provided pursuant to Art. 12, para. 4 of the Protection of Persons Reporting or Public Disclosure of Violations Act (”ZZLPSPOIN“).

Who has the right to send signals?

• current or former employees of ours;
• persons working under a civil contract for the Company;
• persons engaged in liberal professions or handicrafts;
• volunteers and interns in the Society;
• employees of our contractors, subcontractors or suppliers;
• job applicants or participants in competitions for a certain position in the Company;
• all persons to whom information about infringements has become known in a work context.

Important!Anonymous signals are NOT considered.

What violations can you report?

For violations of Bulgarian and European legislation in various fields, among which:

• public procurement;
• public health;
• safety of transport;
• consumer protection;
• the protection of privacy and personal data;
• the security of networks and information systems;
• infringements related to cross-border tax schemes;
• committed a crime of a general nature;
• labor legislation;
• legislation related to the performance of civil service;
• the rules for payment of due public state and municipal debts and other areas specified in the ZZLPSPOIN.

Important!Signals of violations that do not fall within the scope of ZZLPSPOIN are not considered.

How can you report to “PIRIN - SHARLOPOV HOTELS” Ltd.?

You may submit a written report by filling out a sample form in one of the following ways:

• personally, to our employee in charge of the alerts;
• electronically by sending it to the following e-mail: trz@parkhotelpirin.com
• by post or by courier service — to the address of “PIRIN - SHARLOPOV HOTELS” Ltd with an explicit indication as the addressee of the postal/courier shipment the person responsible for ZZLPSPOIN or writing on the mailbox/courier shipment a text indicating that they contain a ZZLPSPOIN signal.

Important!The alerts must be signed by the persons submitting them. When submitted electronically, the form shall be signed with a qualified electronic signature.

Important! The form is NOT mandatory, but is for your convenience and contains the mandatory data that you must fill in. If your If the alert does not comply with any of the legal requirements, our alert officer will send you a message to correct the irregularities within 7 days of receiving the alert. If the irregularities are not corrected within this period, the alert along with the attachments to it will be returned to you.

It is a good idea to attach all the written evidence you have. You may also indicate persons who could confirm the reported data or provide additional information.

You can give an oral signal in one of the following ways:

• on the phone of our officer in charge of alerts- 0746 35643;
• In a personal meeting with our officer in charge of alerts, which you have agreed in advance on the specified phone.

In these cases, our alert officer will fill in the data in the form according to the template and will give you the opportunity to check, correct and agree with the text of the conversation in writing, as well as the content of the form by signing them.

What happens after the signal is given?

• We will confirm receipt within 7 days and register it with a unique identification number. If the alert does not comply with the requirements of the law, we will notify you to correct the irregularity within 7 days.
• A verification will be carried out on the signal by a person who does not have a conflict of interest.
• Within three months of confirming receipt of the alert, we will provide you with feedback with the results of the verification and the actions taken.

What protection do whistle-blowers have?

• Persons entitled to report, as well as related persons (e.g. colleagues and relatives), are protected against unjustified disclosure of their identity, except in cases permitted by law.
• It is forbidden to take retaliatory measures against protected persons, namely: temporary dismissal, dismissal, demotion, negative assessment for work, application of property and disciplinary responsibility, physical and verbal coercion, threat, hostility and damage to their dignity, discrimination, etc.

What are the conditions for granting protection?

• The reporting person must have good reason to believe that the information submitted about the breach in the alert was true at the time of filing and that this information falls within the scope of the ZZLPSPOIN; and
• The violation report was submitted under the conditions and in accordance with the procedure of ZZLPSPOIN.

Important!Persons identified in the alert as violators shall be entitled to compensation for all material and non-pecuniary damage where it is established that the reporting person knowingly made a false report.

How can you report to the DATA PROTECTION COMMISSION?

The Commission for Personal Data Protection is the Central Authority for External Reporting. You can also submit your alert directly to it in one of the following ways:

• in writing:
  
  • by e-mail: whistleblowing@cpdp.bg  
  • by mail to the address: gr. Sofia 1592, blvd. “Prof. Tsvetan Lazarov” № 2
  • through the Secure Electronic Delivery System
  • via the website of the Commission for Personal Data Protection
    

• oral— on the spot in the CPDP at the address: Gr. Sofia 1592, blvd. “Prof. Tsvetan Lazarov” № 2

You could use the sample form for reporting violations, which can be downloaded from the CPDP website. The form is optional. However, if you decide to use it, you only have to fill in Part I — V inclusive and sign it: when sending the form by mail — with a handwritten signature; when sending by e-mail — with a qualified electronic signature.

If you use the Secure Electronic Service System, the CPDP employee responsible for examining the alert will contact you in order to fill in the Form for registering an alert for submitting information about violations under the ZZLPSPOIN.

FOR FILING REPORTS OR PUBLIC DISCLOSURE OF FALSE INFORMATION IS SUBJECT TO ADMINISTRATIVE CRIMINAL LIABILITY UNDER ART. 45 FROM ZZLPSPOIN.