I.Policy statement

Strypes EOOD(hereinafter referred to as “Strypes”) is committed to conducting its business with honesty and integrity. If, at any time, this commitment is not respected or appears to be in question, Strypes will endeavor to identify and remedy such situations. Therefore, it is our policy to ensure that when a person has reasonable grounds to believe that a Union or local law is breached or it is about to be breached, it denounces the irregularities.

II.Purpose

The policy has been put in place to ensure any concerns raised regarding a misconduct or improper state of affairs or circumstances in relation to the Strypes business are dealt with effectively, securely, appropriately, and in accordance with the DIRECTIVE (EU) 2019/1937 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 October 2019 on the protection of persons who report breaches of Union law and the Bulgarian Act on  Protection of persons, reporting information, or publicly disclosing information about breaches.

Strypes encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal.

III.Definitions

Hereunder the following terms shall have the following meanings:

– Employee: a person, employed or otherwise, working for the company and its group companies, i.e.:

• employees, self-employed workers, volunteers, unpaid trainees, shareholders and members of supervisory bodies;
• independent third-party contractors, subcontractors and suppliers;
• ex-workers and future workers, being all persons reporting breaches in a professional as opposed to private context.;

– Company: Strypes

– Management: the CEO and COO of Strypes

– CEO: the Chief Executive Officer of Strypes

– Manager: the person directly managing the employee;

– Confidential adviser: the person designated by the Management to act in that capacity for the company and its group companies;

– Retaliation: any direct or indirect act or omission which occurs in a work-related context, is prompted by internal or external reporting or by public disclosure, and which causes or may cause unjustified detriment to the reporting person.

– Suspected irregularity: a suspicion based on reasonable grounds with regard to the company and in connection with:

• an (imminent) criminal offense;
• an (imminent) violation of laws and regulations;
• an (imminent) intentional provision of incorrect information to public bodies;
• a violation of rules of conduct applicable within the company;

or

• (imminent) intentional suppression, destruction or manipulation of information regarding those facts;
• Any legal breach, misconduct or behavior that one is uncomfortable with.

An employee having a suspected irregularity is not expected to prove the correctness of an assertion, but one must be able to demonstrate that sufficient grounds exist for a reasonable conviction that something is wrong.

IV.Reporting to the confidential adviser

4.1. Unless an exception applies as referred to in article 5.2, employees shall report in writing and submit reports by email at WB@strypes.eu or report by telephone suspected irregularities internally to the confidential advisers listed below Strypes HR Manager, IT Manager and Finance Manager.

When the report is received on the aforementioned email, the report shall be appointed to the specific confidential advisor according to the concerned field.

Employee shall receive an acknowledgement of receipt of the report within 7 days. At the whistleblower’s request, the abovementioned channels should also enable reporting by means of physical meetings, within a reasonable timeframe.

4.2. The written information shall be submitted by the sender by filling in an official form, approved by the national authority for external information reporting. The verbal report shall be documented by the manager or confidential adviser by filling in the form and he/she shall ask the whistleblower to sign it if wishes. The manager or confidential adviser shall procure that the Management shall be informed immediately of a suspected irregularity and of the date on which it was reported, and he shall procure that the Management receives a copy of the record. If the whistleblower reported to the manager, the latter is obliged to immediately inform one of the confidential advisers.

4.3. The Confidential Adviser shall send a confirmation of receipt to the employee who reported the suspected irregularity within 7 days after the reporting date. The confirmation shall refer to the original report.

4.4. Immediately after the employee’s report, an investigation into the suspected irregularity shall be initiated by the Confidential adviser.

4.5. The employee who has reported the suspected irregularity and the person to whom he has reported shall keep the report confidential. No information shall be provided to third parties in or outside the company and its group companies without the consent of the confidential adviser. In providing information, the name of the employee shall not be disclosed and information shall otherwise be provided in such a manner as to safeguard where possible the anonymity of the employee.

4.6. Within eight weeks from his internal report, the employee shall be informed in writing, by the confidential adviser about the Management’s position with regard to the suspected irregularity and the action taken as a consequence of the employee’s report.

4.7. If no position can be given within eight weeks, the employee shall be notified thereof by the confidential adviser and be given an indication as to when he will be informed of the Management’s position. However, feedback entailing actions or lack thereof must be given within 3 months from the date of the acknowledgement of receipt.

V.Reporting to the CEO

5.1. The employee may report the suspected irregularity to the CEO, if:

• а.he disagrees with the position referred to in article 4.6;
• b.he has not been given a position within the requisite period, as referred to in article 4.6 and 4.7;
• c.the period as referred to in article 4.7 is, given all circumstances, unreasonably long and the employee has objected against this to the confidential adviser, but the latter has not indicated a shorter, reasonable period;
• d.the suspected irregularity concerns a member of the Management, or
• e.an exception as referred to in the next paragraph applies.

5.2. An exception as referred to in the previous paragraph applies if there is

• a.situation in which the employee has reasonable grounds to fear that an internal report would lead to countermeasures or
• b.previous, duly submitted, internal report about essentially the same irregularity, which has not removed the irregularity.

5.3. The CEO shall make a written record of the report and of the date of its receipt and shall have the employee concerned sign the record for approval. The employee shall receive a copy of the record.

5.4. The CEO shall send a confirmation of receipt to the employee who reported the suspected irregularity. If the employee had previously reported the suspected irregularity, the confirmation shall refer to the original report.

5.5. Immediately after the employee’s report, the CEO shall start an investigation into the suspected irregularity involving the respective professionals.

5.6. The employee who has reported the suspected irregularity and the person to whom he has reported shall keep the report confidential. No information shall be provided to third parties in or outside the company and its group companies without the consent of the CEO. In providing information, the name of the employee shall not be disclosed and information shall otherwise be provided in such a manner as to safeguard where possible the anonymity of the employee.

5.7. Within eight weeks from his internal report, the employee shall be informed in writing by the CEO of the Management’s position with regard to the suspected irregularity and the action taken as a consequence of the employee’s report.

5.8. If no position can be given within eight weeks, the employee shall be notified thereof by the CEO and be given an indication as to when he will be informed of the Management’s position.

VI.Acting in good faith

Any person who files a complaint alleging misconduct must act in good faith and have reasonable grounds to believe that the information disclosed indicates wrongdoing.

No reporting person who makes a denunciation in good faith will be subject to retaliation. Retaliation is  any direct or indirect act or omission which occurs in a work-related context, is prompted by internal or external reporting or by public disclosure, and which causes or may cause unjustified detriment to the reporting person.

However, making allegations that are deemed unfounded and malicious or knowingly false may result in disciplinary action up to and including termination of employment.

VII.Legal protection

7.1. The position of employees who have reported a suspected irregularity in accordance with these rules shall not be affected in any way as a result of the report. If it should become clear that the procedure has not been used in good faith (for example, in case of a personal grudge against another employee), this will constitute misconduct.

7.2 Retaliation is prohibited. More specifically, the following are prohibited:

• temporary suspension, dismissal or application of another ground for termination of the legal relationship, under which the person is employed;
• demotion or delay in promotion;
• a change in the place or nature of work, the length of working hours or a reduction in remuneration;
• refusal to provide training to maintain and improve the professional qualification of the worker or employee;
• negative evaluation of work, including in a job recommendation;
• application of property and/or disciplinary liability, including imposition of disciplinary penalties;
• coercion, rejection, threats to take retaliatory actions or actions, expressed physically, verbally or in any other way, which are intended to harm the dignity of the person and create a hostile professional environment;
• direct or indirect discrimination, unequal or unfavorable treatment;
• taking away the possibility to switch from a fixed-term employment contract to an employment contract for an indefinite period of time, when the worker or employee had a legal right to be offered a permanent job;
• preterm termination of a fixed-term employment contract or refusal to re-conclude it, when such is permissible by the law;
• harms, including to the person’s reputation, in particular in social networks, or financial losses, including loss of business and loss of income;
• inclusion in a list, drawn up on the basis of a formal or informal agreement, in a sector or in an industry, which may result in the person not being able to start working or not being able to supply a good or service in that sector or industry (blacklist);
• early termination or cancellation of a contract for the supply of goods or services when the person is a supplier;
• termination of a license or permit;
• directing the person to a medical examination.

7.3 From the moment that an employee can demonstrate that (i) he/she disclosed information (by internal or external reporting or by public disclosure) and that (ii) he/she encountered any act of retaliation, the burden of proof shifts to the natural or legal person responsible for that act or retaliation. Hence, it is for the later to demonstrate justifiable grounds.

7.4 As soon as the internal investigation is closed and the employee is correctly informed of its outcome, the legal entities must keep records of every report received, in compliance with the confidentiality requirements. However, reports must be stored for no longer than is necessary and proportionate to comply with the Whistleblower Directive or with requirements imposed by Union or national law.

*The Company may unilaterally introduce, vary, remove or replace this policy at any time.