Whistleblowing Policy at Boldare

1. General Assumptions

   1. At Boldare, we aim to create a work environment that is fair, safe, and based on mutual respect.

   2. Therefore, we have implemented a whistleblowing policy that regulates the reporting of irregularities — either anonymously or openly — in a secure and confidential manner.

   3. The whistleblowing policy at Boldare was established after consultations with employees and collaborators. Everyone working with or starting a collaboration with Boldare has access to this policy through the organization's internal and external channels.

2. Who Can Report?

   1. Anyone cooperating with Boldare under an employment contract or any other legal basis — including interns, trainees, or volunteers, as well as individuals working for affiliated entities (personally, financially, and organizationally) — can make a report.

   2. Reports can only be made in good faith and regarding matters that the person reporting has knowledge of. This means that when making a report, you must act honestly, in the interest of the organization or the public, and aim to contribute to corrective actions within the organization.

3. What Should Be Reported?

   1. We want the whistleblowing platform to be a safe space, free of any form of discrimination, and one that respects everyone contributing to our organization.

   2. The subjects of reports can include:

      1. Violations of internal organizational norms, rules, and processes at Boldare;

      2. Financial issues and preventing money laundering and terrorism financing, including corruption, bribery, and fraudulent financial practices;

      3. Violations of privacy and personal data protection;

      4. Violations related to health and safety at the workplace, or service delivery.

4. How to Report?

   1. The internal channel dedicated to handling reports is a secure and independent platform:app.sygnalista24.info/whistleblowing-boldare

   2. The identity of the person reporting is fully anonymized, and the platform removes all metadata from submitted attachments. Reports are encrypted.

5. What Happens After a Report?

   1. You will receive confirmation of your report's receipt on your platform account within 7 days. Keep your login and password, as the person analyzing the report may communicate with you through a chat if further clarification is needed.

   2. After receiving the report, depending on its content, the individuals analyzing the issue will pass the information and recommendations for further action to the dedicated person in Boldare.

6. External Channels According to Polish Law

   1. Apart from internal reporting channels, national laws allow the use of external channels offered by public authorities and the National Labor Inspectorate if:

      1. The organization has failed to take action despite your report;

      2. You have legitimate grounds to believe that the violation of the law could cause irreversible harm to the public interest;

      3. You believe reporting could expose you to negative actions by the organization.

7. Whistleblower Protection

   1. Using the whistleblowing platform — whether anonymously or with your name — must never result in negative consequences for the person making the report or anyone related to them. As a whistleblower acting in good faith, in the organization's interest or the public interest, you are protected by law.

   2. Retaliation or negative actions against a whistleblower for making a report is punishable by a fine or even imprisonment. Boldare ensures your safety through an independent role dedicated to handling reports.