“AS Hotels” EOOD, registered in the Commercial Register and the Register of Non-Profit Legal Entities with EIC 131261782, publishes this Information on the terms and conditions for reporting violations on the basis of Art. 12, para. 4 of the Law on protection of persons reporting or publicly disclosing information on breaches, hereinafter referred to as the Law, which defines the terms and conditions for receiving and investigating reports of violations, as well as ensuring the protection of persons in the company who submit reports or publicly disclose information about violations of Bulgarian legislation or acts of the European Union that they became aware of while performing their work or official duties or in another work context.

Applicability

This information applies in relation to whistleblowing in the following areas:

1. Violations of Bulgarian or EU legislation in the field of:

• Public procurement;

• Financial services, products and markets and the prevention of money laundering and terrorist financing;

• Product safety and compliance;

• Transport safety;

• Environmental protection;

• Radiation protection and nuclear safety;

• Food and feed safety, animal health and welfare;

• Public Health;

• Consumer protection;

• Protection of privacy and personal data;

• Security of networks and information systems.

  2. Infringements affecting the financial interests of the European Union within the meaning of Article 325 of the Treaty on the Functioning of the European Union.

  3. Infringements of internal market rules within the meaning of Article 26(2) of the Treaty on the Functioning of the European Union, including European Union rules and Bulgarian legislation on competition and State aid.

  4. Infringements relating to cross-border tax schemes the purpose of which is to obtain a tax advantage which is contrary to the object or purpose of the applicable corporate tax law.

  5. An offence of a general nature committed of which a person becomes aware in connection with the performance of his or her work or in the course of the performance of his or her duties.

  6. Reporting or public disclosure of information about violations of Bulgarian legislation in the field of:

• The rules for the payment of outstanding public state and municipal claims;

• Labour legislation;

• Legislation relating to the performance of public service.

Whistleblowing channels

Whistleblowing shall be prioritised through the internal whistleblowing channel as per the information in the sections below.

In the event of a reasonable belief that the whistleblower is at risk, the whistleblowing may be submitted to the national external whistleblowing authority, the Commission for Personal Data Protection (CPDP). Information on how to report under the Act can be found on the website of the CPDP: https://www.cpdp.bg.

Whistleblowing via the internal channel

A complaint may be submitted in person or through a proxy with express written authority

in one of the following ways:

• By e-mail: whistleblow@splf.eu;

• At the following address: Sofia, 2 Biser Str., apt. 5, to the attention of: Person in Charge LPPRPDIB (Law on protection of persons reporting or publicly disclosing information on breaches). The letter should be marked ‘Confidential’;

• In a personal meeting with the responsible person, after arranging a contact number.

The alert should contain the whistleblower’s details, which will not be shared with others except for the purposes of the inspection. A written whistleblowing report must be signed in person by the whistleblower and submitted by completing a form on the Privacy Commission’s template (available to download here).

An alert may also be made in free text, in which case it must contain at least the following information: the three names of the person making the report, address, telephone number and e-mail address, if available; the name of the person against whom the report is made and his or her place of work, if the report is made against a specific person and he or she is known to you; specific details of the offence or of a real risk of such an offence; the place and period of the offence, if any; a description of the act or the situation and other circumstances, insofar as such are known to the reporting person; date of submission of the report; signature, electronic signature or other identification of the sender.

A verbal alert is filed by the responsible official filling out the form according to the CPDP model, and the person submitting the report is offered the option of signing it based on their preference.

The alert may be accompanied by any sources of information supporting the allegations made and/or by reference to documents, including details of persons who could corroborate the information reported or provide additional information.

The alert may be accompanied by any sources of information supporting the allegations made and/or by reference to documents, including details of persons who could corroborate the information reported or provide additional information.

Registration of an alert submitted via an internal channel

The alert received through the company’s internal channel shall be registered in the internal register for complaints under the LPPRPDIB (Law on protection of persons reporting or publicly disclosing information on breaches), together with the unique identification number of the alert issued by the CPDP. The whistleblower shall be notified of the registration.

Examination of an alert submitted through an internal channel

Alerts shall be dealt with under the terms and conditions of the LPPRPDIB. In the case of legitimate complaints, i.e. those within the scope of the LPPRPDIB, an investigation shall be carried out within three (3) months of the registration of the complaints, during which the appropriate actions shall be taken.

In connection with an ongoing investigation, the person responsible shall have the right to request additional information from the whistleblower as well as from third parties, to hear the person concerned, who in turn shall have the right to object and to present evidence in defense of his allegations. Where action is required with the assistance of a public authority, the whistleblower may be referred to the CPDP, which shall be notified to the whistleblower in due time.

We do not review alerts that:

• Are submitted anonymously, unless the person in charge decides to initiate an investigation;

• Relate to infringements committed more than two (2) years ago;

• Contain allegations of infringements outside the scope of the Act.

  .

Additional information

For more information on the rights and obligations under the Law on protection of persons reporting or publicly disclosing information on breaches, you can read the full text of the Act via this link. The Frequently Asked Questions section on the CPDP website regarding the application of the LPPRPDIB is available through this link.