Whistleblowing Policy

Every natural person has the right to report violations that they became aware of in the context of performing their duties in the Group or their employment in the Group or their cooperation with it.

Violations of EU law related to the activities of the HELLENiQ ENERGY Group Companies and concerning matters regulated by European Union legislation.

Possible violations include:

• Public procurement
• Financial services, products, and markets, as well as prevention of money laundering and terrorist financing
• Product safety and compliance
• Transport safety
• Environmental protection and public health
• Consumer protection
• Privacy and personal data protection, as well as the security of network and information systems
• Violations affecting the financial interests of the European Union
• Infringements related to the internal market, including breaches of Union competition and State aid rules, as well as violations of corporate tax regulations or arrangements intended to secure a tax advantage that defeats the object or purpose of the applicable corporate tax legislation, as further described in Article 4 of the reporting policy.

The Whistleblowing Officer shall inform the Reporting Person in writing of the progress of the investigation in the case of a named report. Such information shall be provided within a reasonable time, which shall not exceed three months from the date of notification of receipt of the respective report.

The Whistleblowing Officer is responsible for receiving reports submitted through the Group’s designated channels and managing them as follows:

• Receiving and recording the report in a special register.
• Providing written confirmation of receipt within seven (7) days, in the case of a named report.
• Assessing whether the report falls within the scope of this Policy, with the assistance of the Group Legal Department.
• Archiving the report if it is unclear, does not concern an EU law violation, or lacks serious indications of such a violation. The Reporting Person will be notified accordingly.
• If the report falls within the scope of this Policy, the Reporting Person will receive written notification of the applicable protection measures.
• If the report is valid and within the Policy’s scope, the Whistleblowing Officer forwards it to the Report Evaluation Committee (as provided in Article 20 of the HELLENiQ ENERGY Group Code of Conduct), which has exclusive authority over the investigation.
• The Whistleblowing Officer will provide the Reporting Person with written updates on the investigation’s progress within a reasonable period, not exceeding three months from the date of receipt of the report.

The procedure is described in more detail in Article 6.1.4 of the Whistleblowing Policy.

Yes, through the platform, by searching for the specific report submission number, which you should have noted when submitting the report.

A report may be submitted anonymously. However, the Group has a fundamental obligation to protect all Reporting Persons.

The Group ensures the protection of individuals submitting a report, regardless of its validity, provided that at the time of submission, the Reporter had reasonable grounds to believe that the report was truthful and concerned a violation of EU law. In such cases, the Whistleblowing Officer applies the protective measures provided by law against retaliation.

The protection framework remains in place even if the investigation does not confirm the reported violation, as long as the report was not made maliciously.