Whistleblowers

Director of Petrans Prikolice d.o.o., Peter Katrašnik, as the person responsible for establishing an internal reporting channel, adopts the following

REGULATIONS ON THE ESTABLISHMENT OF AN INTERNAL CHANNEL FOR REPORTING VIOLATIONS AND PROTECTION OF WHISTLEBLOWERS

Article 1

(General Provisions)

Petrans Prikolice d.o.o. (hereinafter: the obligated party) aims to ensure information on the process of handling internal reports in accordance with the Whistleblower Protection Act, which must provide completeness, integrity, and confidentiality of information and prevent unauthorized persons from accessing the content of reports, data about the whistleblower, and persons involved in the report. Therefore, it adopts the Regulations on the Establishment of an Internal Channel for Reporting Violations and Protection of Whistleblowers (hereinafter: the Regulations).

The management of the obligated party is aware of the importance of ethical and lawful business conduct and commits to:

• Not attempting to discover the identity of the whistleblower;
• Not retaliating and prohibiting employees of Petrans Prikolice d.o.o. from retaliating;
• Encouraging employees to report errors and potential violations, even if suspicious, through the internal reporting channel, as this will ensure effective handling of reports and quick correction of errors and violations.

Article 2

(Appointment of Administrative Staff)

The Commissioner may be assisted by administrative staff appointed by the director by decision.

The administrative staff handles tasks related to receiving and recording internal reports.

Article 4

(Contact Information for Reporting)

Reports are typically submitted using the form from Annex 2 of these Regulations and received in the following ways and addresses:

• By email to: damir.milkovic@petrans-prikolice.hr
• Personally to the Commissioner by prior arrangement via phone or email.

Article 5

(Contact Information for Receiving Reports)

Reports are typically submitted using the form from Annex 2 of these Regulations and received in the following ways and addresses:

• By email to: damir.milkovic@petrans-prikolice.hr
• Personally to the Commissioner by prior arrangement via phone or email.

Article 5

(Procedure for Receiving Internal Reports)

The whistleblower may submit a report in writing or orally (by phone or in person).

When the whistleblower submits a report in person or by phone, the Commissioner may record the statement. The whistleblower is informed about the recording before it starts.

If the oral report is not recorded, the Commissioner creates a precise record of the report and provides it to the whistleblower for review and signature.

Article 6

(Recording of Reports)

The Commissioner (or authorized administrative staff) records the report in a manual record kept in an Excel spreadsheet for each year, separately from other matters, to make it inaccessible to unauthorized persons.

The record of received reports (record data) contains the following information:

• Case number, date of receipt, area of violation, date of acknowledgment of receipt, date of feedback to the whistleblower, date of reporting to the management, information about the whistleblower, intermediary, related persons, data about the person involved in the report and persons who can assist in the investigation of the reported violation (real name or pseudonym, postal address, email address, phone number, and other contacts)
• Material submitted by the persons mentioned above, material created in the process of handling the report, including the recording or record of the conversation or call in case of an oral report.

Data about the whistleblower and the source of the violation are recorded in a way that allows their later easy deletion or destruction (e.g., in a separate list linked to the case number or using a code name).

Electronic reports with attachments are stored in the information system, and physical reports are kept in a special locked cabinet in the Commissioner’s office. Physical reports are treated in terms of storage and handling both physically and technically as if they were classified internal or business secrets.

Data about the whistleblower and the source of the violation are deleted from the records after five years, and the report to the management and record data are kept for 10 years.

Article 7

(Duties of the Commissioner and Protection of Whistleblowers)

The Commissioner acts carefully, confidentially, and independently of instructions in individual cases. The Commissioner must not disclose the identity of the whistleblower, except under conditions specified by the Whistleblower Protection Act.

The Commissioner has access to documents relevant to handling the report, and employees are required to provide assistance and information necessary for his work. The Commissioner uses the data he becomes aware of only for the purpose of processing the report and eliminating violations.

The Commissioner performs tasks established by Article 10 of the Whistleblower Protection Act, including advising and assisting the whistleblower regarding feedback measures and this act.

The whistleblower may ask the Commissioner for clarifications on protection in case of prohibited retaliatory measures, as specified in Chapter 7 of the Whistleblower Protection Act.

Article 8

(Procedure for Handling Internal Reports)

The Commissioner handles reports in the order they are received.

In case of suspicion of endangerment of human life or significant material damage based on the report, the Commissioner processes the report with priority.

Article 10

(Handling of Reports)

The Commissioner is obliged to inform the whistleblower about the possibilities of internal and external reporting and public disclosure and protection against retaliatory measures.

The Commissioner reviews the report and determines which person or internal organizational department in Petrans Prikolice d.o.o. is responsible for resolving the violation referred to in the report. He informs the head of the responsible department about the description of the reported violation and his proposals for measures. In the notice, he indicates that it is the processing of a report in accordance with the Whistleblower Protection Act and sets a deadline for feedback on the measures taken or proposed to resolve the violation and against the perpetrator.

The Commissioner, at his discretion or on the suggestion of the head of the department responsible for resolving the violation, may conduct a conversation with the whistleblower and the person involved in the report to ascertain circumstances important for identifying and resolving the violation.

The Commissioner completes the handling of the report within three months of its receipt with a report on the completed handling, stating whether the report is unfounded or for what reasons, and if the report is founded, lists the proposed and implemented measures to stop the violation, eliminate the consequences of the violation, and prevent future violations, his conclusions on the success of the implemented measures, and any proposed and implemented measures for the protection of the whistleblower.

The Commissioner, upon completing the handling of the report, informs the whistleblower about the foundedness of the report, the proposed and implemented measures, the outcome of the procedure, or the status of the procedure with the internal report if the measures to eliminate the violation have not been completed within three months. Oral notification is recorded in the record of reports.

The Commissioner acts according to the previous paragraph also in the case of an anonymous report if the whistleblower indicated where the notification should be sent according to the previous paragraph.

Article 11

(Notifying the Management)

The Commissioner, after providing feedback to the whistleblower or no later than one month, prepares a report for the management. The report describes the reported violation, proposed and implemented measures to eliminate it, and assesses the risk of future violations. The report must not include information about the whistleblower or the perpetrator.

The Commissioner, based on a written invitation from the director, prepares a report on the report before the deadline from the previous paragraph.

Article 12

(Annual Report)

The Commissioner prepares a draft statistical report for the Anti-Corruption Commission by February 1 of the current year for the previous calendar year, with content in accordance with the sixteenth paragraph of Article 9 of the Whistleblower Protection Act.

Based on the draft statistical report from the previous paragraph, the obligated party submits the required data to the Anti-Corruption Commission by March 1 of the current year via an electronic form, indicating the information about the Commissioner.

Article 13

(External Reporting)

The whistleblower may submit a report directly through the external reporting channel if an internal reporting channel has not been established, if the internal report cannot be effectively resolved, or if the whistleblower believes there is a risk of retaliatory measures in the case of an internal report.

The whistleblower may publicly disclose the violation under the conditions specified in Article 18 of the Whistleblower Protection Act.

Article 14

(Informing Employees and Other Persons in the Working Environment of the Obligated Party)

The person for administrative assistance, in agreement with the Commissioner, prepares and updates the content of the website.

Contents are published on the bulletin board in the premises of Petrans Prikolice d.o.o. and on the website at: www.petrans-prikolice.hr.

Article 15

(Updating the Document)

Amendments and supplements to these Regulations are adopted in the same manner as the Regulations.

Article 16

(Effective Date and Publication)

The act comes into force on December 15, 2023.

This internal act with annexes is published on the bulletin board and is available in the human resources department.

Petrans Prikolice d.o.o.