INFORMATION

ON THE CONDITIONS AND PROCEDURE FOR INTERNAL SUBMISSION OF SIGNALS

PayMan Group Ltd

This information is provided pursuant to Art. 12, para. 4 of the Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations.

1. Who has the right to report?

• current and/or former workers and employees;

• persons working under a civil contract;

• persons practicing free professions and/or crafts;

• volunteers and interns;

• contractors, subcontractors and/or suppliers;

• job candidates who participated in a competition or other form of selection for employment and in this capacity received information about a violation;

• persons who report violations that became known to them in a work context.

Important! Anonymous reports are NOT considered.

2. What violations can you report? For violations of Bulgarian and European legislation in various areas, including: • public tenders; • public health; • safety of transport; • consumer protection; • protection of privacy and personal data; • security of networks and information systems; • violations related to cross-border tax schemes; • committed crime of a general nature;• the labor legislation; • the legislation related to the performance of public service; • the rules for payment of due public state and municipal receivables, etc. areas specified in Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations.

Important! Reports of violations that do not fall under the scope of Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations, as well as reports of violations committed more than 2 (two) years ago, are not considered.

3. How can you submit a report to " PayMan Group" OOD ?

You can submit a written report by completing a sample form in one of the following ways:

• in person to the responsible employee or by phone - +359894500199, +359899134402 ;

• electronically to the following email: whistleblowing@mrpayman.com ;

  by mail or by courier service - to the address of " PayMan Group" OOD in the city of Sofia, "Bulgaria" Blvd. No. 102, fl. 3, apartment office 26 with an explicit indication as the addressee of the postal/courier shipment of the responsible person or writing on the postal envelope/courier shipment a text indicating that they contain a signal under Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations.

  Important! The reports must be signed by the persons submitting them. When submitted electronically, the form is signed with a qualified electronic signature. Important! The form is NOT mandatory, but is for your convenience and contains the mandatory data that you must fill out. If your report does not meet any of the legal requirements, our employee responsible for reports will send you a notice to remedy the irregularities within 7 days of receiving the report. If the irregularities are not corrected within this period, the signal together with its attachments will be returned to you.

  It is a good idea to attach any written evidence you have. Also, you can designate persons who could confirm the reported data or provide additional information.

  You can make a verbal report in any of the following ways:

  • on the phone of our employee in charge of signals - +359894500199, +359899134402 ;

  • at a personal meeting with our employee in charge of signals, which you have arranged in advance on the specified phone.

  In these cases, our whistleblowing officer will fill in the data in the template form and give you the opportunity to check, correct and agree to the text of the conversation in writing, as well as the content of the form by signing it.

  4. What happens after the report is filed?

  • We will confirm receipt within 7 (seven) days and register it with a unique identification number. If the signal does not meet the requirements of Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations , we will notify you to remove the irregularity within 7 days.

  • An investigation of the report will be carried out by a person who does not have a conflict of interest.

  • Within 3 (three) months of confirming the receipt of the signal, we will provide you with feedback with the results of the inspection and the actions taken.

  5. What protections do whistleblowers have?

  • The persons who have the right to file reports, as well as the persons related to them (eg colleagues and/or relatives), are protected against unfounded disclosure of their identity, except in the cases allowed by Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations .

  • It is prohibited to take retaliatory measures against the protected persons, namely: temporary suspension from work, dismissal, demotion, negative evaluation of the work, application of property and disciplinary responsibility, physical and verbal coercion, threat, hostility and violation of their dignity , discrimination, etc.

  6. What are the conditions for granting protection?

  • The person submitting the report must have reasonable grounds to believe that the information submitted about the violation in the report was correct at the time of submission and that this information falls within the scope of the Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations and

  • The violation report was submitted under the conditions and according to the procedures of the Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations.

  Important! Persons named in the report as violators are entitled to compensation for all pecuniary and non-pecuniary damages when it is determined that the whistleblower knowingly filed a report with false information.

  7. How can you report to the COMMISSION FOR THE PROTECTION OF PERSONAL DATA? The Commission for the Protection of Personal Data is the Central Authority for external whistleblowing . You can also submit your report directly to them in one of the following ways:

  • in writing:

  • by email whistleblowing@cpdp.bg ;

  • by mail to the address: Sofia 1592, Prof. Blvd. Tsvetan Lazarov" No. 2;

  • through the Secure Electronic Delivery System.

  • orally - on site at the CPLD at the address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2.

  You could use the sample Whistleblower Registration Form published on the CPLD website. The form is optional. However, if you decide to use it, you must complete only Parts I - V, inclusive, and sign it: when sending the form by post - with a handwritten signature; when sending by e-mail - with a qualified electronic signature. If you use the System for secure electronic delivery, the employee of the CPLD responsible for considering the report will establish contact with you in order to fill in a Form for registering a report for submitting information on violations under the Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations.

  Please also familiarize yourself with:

  Privacy Notice for Whistleblowers