Whistleblowing Policy

Universuss internal rules on whistleblowing

Not only do the Universuss group companies work in compliance with the provisions of applicable laws and regulations, but our companies also follow high corporate governance standards.

We have drawn up our Code of Conduct, which sets out guidelines for the company's management and employees on how to interact with colleagues, clients, business partners, and competitors. The Code of Conduct defines, inter alia, our principles with respect to fair competition, confidentiality, conflict of interest, and prevention of corruption risks.

At Universuss group, we strive to create a working environment that encourages mutual respect and trust and enables employees to openly report on any actions within the company that are in conflict with the normative framework or on actions that violate the principles set out in the Universuss group's Code of Conduct. For our employees to know how to act, we have drawn up our internal whistleblowing rules.

Internal whistleblowing

A whistleblower may be a natural person who reports on a possible violation that may harm the interests of the company and/or society if the person considers such information to be true and it has become known to them while fulfilling work duties or establishing legal relations related to the fulfilment of work duties.

Deliberate provision of false information does not constitute whistleblowing, and the person providing such information may be held liable in compliance with applicable laws and regulations. Also, reporting on infringement of personal interest is not regarded as whistleblowing.

Internal whistleblowing is a process whereby a whistleblower reports on unlawful actions at workplace or on actions that violate the principles set out in the Universuss group's Code of Conduct.

Content of a whistleblower's report

When reporting a violation, a whistleblower must provide the following information:

• the whistleblower's name, surname, and contact details;
• details related to the violation (or possible violation), separately indicating facts and persons involved, as well as enclosing evidence if such evidence exists;
• how information related to the violation came into whistleblower's possession (for example, by fulfilling work duties);
• whether the violation has been reported previously.

Examination of a whistleblower's report

At the Universuss group companies, Head of Human Recourses is responsible for implementation of the whistleblowing policy.

The person responsible:

• accepts and registers a whistleblower's report;
• performs initial examination of the report and decides on the further course of action;
• duly stores and destroys the report and documents related to it;
• provides consultations related to whistleblowing if necessary.

The report is examined promptly, and with due care, ensuring feedback to the whistleblower and a course of action suitable to the situation, informing external bodies if necessary.

Protection provided by the whistleblowing policy

Personal data contained in a whistleblower's report is protected in compliance with applicable laws and regulations. After reception of a whistleblower's report, the submitter's personal data is pseudonymised.

A whistleblower's personal data, the report, and enclosed written or material evidence, as well as the examination materials of the whistleblower's report have the status of restricted access information.

Protection of personal data

The purpose of processing personal data upon examination of a whistleblower's report is to ensure investigation of a possible violation, appropriate protection for the whistleblower, and communication with the whistleblower.

Information availability policy

To ensure availability of information on the internal whistleblowing policy of the Universuss group companies, the whistleblowing rules are published on the company's homepage and intranet. Upon commencement of employment relationship with a Universuss group company, an employee is informed about the whistleblowing policy.