Whistleblowing Mechanism

At Symetrium Sp. z o.o., a Whistleblowing System is in place, constituting a structured sequence of successive actions designed to receive and review incoming reports, and to inform the whistleblower of the outcomes of the investigation.

A whistleblower may include, among others: an employee, former employee, temporary agency worker, an individual providing work under a civil law contract, an entrepreneur, shareholder, partner, member of an organ of a legal person, an individual providing work under the supervision and direction of a contractor, subcontractor, or supplier, a volunteer, trainee, job applicant, or a holder of a commercial power of attorney (prokurent).

This system enables the reporting of acts non-compliant with generally applicable law, as well as violations of internal and corporate regulations, through the communication channels established at Symetrium Sp. z o.o., i.e.:

• sending a letter to the following address: Symetrium Sp. z o.o., ul. Krakowska 280 bud. 200, 32-080 Zabierzów;
• dropping a written report into a dedicated mailbox located at the entrance to the company’s registered office, marked as „WEWNĘTRZNY KANAŁ DOKONYWANIA ZGŁOSZEŃ NARUSZENIA PRAWA”.

A breach of law is an act or omission that is unlawful or intended to circumvent the law, concerning:

1. corruption
2. public procurement
3. financial services, products, and markets
4. prevention of money laundering and terrorist financing
5. product safety and compliance
6. transport safety
7. environmental protection
8. radiation protection and nuclear safety
9. food and feed safety
10. animal health and welfare
11. public health
12. consumer protection
13. protection of privacy and personal data
14. security of network and information systems
15. financial interests of the State Treasury of the Republic of Poland, local government units, and the European Union
16. the internal market of the European Union, including public competition and state aid rules, as well as corporate taxation
17. constitutional freedoms and human and citizen rights – occurring in relations between an individual and public authority organs and not related to the fields specified in points 1–16

Employees are obliged to immediately report any reasonable suspicion of corrupt activities or other misconduct. To this end, the following are provided:

• the aforementioned communication channels allowing employees and external entities to securely (including anonymously) report potential breaches,
• confidentiality of the whistleblower’s data and the submitted information.

The individual authorized to receive internal reports and take follow-up actions shall, upon receiving a report, acknowledge its receipt to the reporting person (except for anonymous reports), verify its validity, and subsequently undertake follow-up actions with due diligence to investigate the circumstances outlined in the report.

Symetrium Sp. z o.o. also maintains a Register of Misconduct (the retention period for reports is 3 years).

If corrupt activities or other misconduct are confirmed, the companies undertake corrective actions designed to prevent similar incidents in the future.