ГЕОТРЕЙДИНГ АД

Employers in the private sector with 50 or more employees who are obliged subjects under Art. 12, para. 1, item 2 of the Act on the protection of persons who report or publicly disclose breaches (Whistleblowers protection act), should provide an opportunity for internal reporting of signals within the meaning of the law. For this purpose, pursuant to Art. 13, para. 1 in connection with Art. 14, para. 5 of the Whistleblowers protection act, the companies of the GEOTECHMIN group - including “GEOTRADING” AD, have concluded an agreement by which they have assigned “GEOTECHMIN” OOD to accept and register signals within the scope of the Act, agreeing that the Company Standard “Red Telephone System” will be used as an internal channel for reporting signals under the Whistleblowers protection act by their employees.

I. Units responsible for receiving and considering signals

for receiving signals – Inspectorate Directorate, “GEOTECHMIN” OOD,

for considering signals – Ruslan Emanuilov, “GEOTRADING” AD, assisted by the Inspectorate Directorate, “GEOTECHMIN” OOD Exceptionally, if the nature of the signal requires it, its review is carried out by the Inspectorate Directorate, “GEOTECHMIN” OOD.

II. Subject of the signals

Violations of Bulgarian legislation or acts of the European Union1 that became known to the whistleblower during or in connection with the performance of his or her employment or official duties or in another work context.

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III. Internal reporting channel

Reports can be submitted in writing:

• - to the e-mail address of the Inspectorate Directorate - inspectorate@geotechmin.com;
• - by mail or in another way to address: Sofia, 9 Lyulin Planina Street, to the attention of the Inspectorate Directorate;
• - the announced channels on the corporate website of “GEOTECHMIN” OOD for reporting violations: https://www.geotechmin.com/

Reports may be submitted verbally by holding a meeting, within an appropriate time frame agreed with the unit responsible for receiving reports, at the request of the reporting person.

IV. Conditions and procedure for submitting reports

Reporting persons shall submit a report to the unit responsible for receiving reports in one of the ways specified in item III.

Reports are submitted by completing the CS 7-10-1 Report Form. The verbal report is documented by filling out the form by an employee from the unit responsible for receiving reports, who offers the whistleblower to sign it if he so wishes.

No proceedings are initiated based on anonymous reports.

Signals that do not fall within the scope of the Whistleblowers protection act and whose content does not provide grounds for considering them plausible are not considered.

Reports that contain obviously false or misleading statements of fact will be returned to the sender with instructions to correct the statements and to assume responsibility for any rebuttal.

If the report does not meet the requirements of the law, the reporting person is notified in order to eliminate the irregularities. If they are not eliminated within 7 days of receiving the report, the report, together with its attachments, is returned to the reporting person.

V.Measures to ensure protection

“GEOTRADING” AD guarantees that all legally permissible measures have been taken so that no retaliatory actions are taken against the company's workers and employees who have filed a report, as well as against persons related to them, in connection with these reports, which are of a repressive nature and put them in a disadvantageous position, nor are they threatened or attempts are made against them for such actions.

Detailed information on the terms and conditions for reporting violations can be found in CS 7-10 “Red Telephone System” of “GEOTREADING” AD.