System for reporting initiatives and irregularities

Statute

System for reporting initiatives and irregularities of the AIUT Group

The purpose of the System for reporting initiatives and irregularities of the AIUT Group (hereinafter referred to as the System of Initiatives) is to ensure the possibility of free reporting of initiatives and irregularities regarding the functioning of the AIUT Group, with clear emphasis on reliable protection of reporting entities against possible retaliation.

1. Applications in the Initiatives System may be made by any economic participant.
2. A notification in the Initiatives System may concern any element of business, including the internal situation of the AIUT Group (e.g. unethical business practices, environmental issues, violations of human rights).
3. Reporting in the Initiatives System is made by sending an e-mail to whistleblowing@aiut.com
4. The notification may be made in a manner enabling the identification of the applicant and anonymously, however, due to the information contained in sec. 11 anonymous reporting is encouraged.
5. In order to report anonymously, the reporting person is obliged to set up an e-mail box with an abstract name for the purpose of making a notification or making a notification in another technically available way. It is emphasized that due to the automatic collection of metadata, it is not possible to ensure full anonymity, while AIUT sp. z o.o. declares that it will not use this data to determine the identity of the applicant
6. Consideration of the application is carried out without information whether the application was made openly or anonymously.
7. Applications are considered by the System of Initiatives Team (hereinafter referred to as ZSI), the current composition of which is provided on the website of AIUT sp. z o.o. The composition of the ZSI and its number may change.
8. ZSI immediately takes actions corresponding to the notification, and after completing the activities, informs the applicant about the actions taken as a result of the notification, conclusions drawn and possible decisions. Information to the applicant is sent no later than within 3 months of receiving the notification to the e-mail address from which the notification was made. The applicant, if necessary and consents to it, may be included in the application examination process.
9. Reporting persons may not suffer negative professional and/or economic consequences as a direct consequence of reporting, i.e. against them as reporting persons. The previous sentence does not apply if the report turns out to be false and made in bad faith, and in such a case only actions are taken in accordance with the provisions of generally applicable law.
10. ZSI members keep a register of notifications, in which they contain at least information about the notification and actions taken in connection with it, applications and decisions, as well as information on the interventions referred to in sec. 11 and, in justified cases, on an ad hoc basis, at least once every 12 months, take steps to verify the effectiveness of the changes resulting from the decisions made as part of the notification procedure.
11. The AIUT Group emphasizes that, apart from members of the Initiatives System Team, in justified cases, e.g. due to a failure, the need to intervene in the event of a hacker attack, actions justified by the need to protect the property of the AIUT Group or resulting from obligations towards public authorities, access to the mailbox referred to in section 3, the notification and data related to it, including the data of the applicant, may be held by third parties, including those responsible for information security and/or ensuring the proper functioning of the IT system in the AIUT Group.
12. The persons referred to in sec. 11, it is forbidden to disclose information about notifications and data enabling identification of the applicant to other third parties, unless the applicant agrees to it in documentary form or it results from the provisions of generally applicable law.
13. If it is legally and technically possible, the persons referred to in par. 11, other than members of the ZSI, are obliged to inform the members of the ZSI about the need to undertake an intervention that may result in access to data concerning the notification and the applicant in advance. If it is not possible to provide information in advance, it is provided immediately. Detected, unreported interventions are reported to the Management Board of AIUT sp. z o.o. in order to take appropriate action against the persons who made them.