WHISTLEBLOWER POLICY
Dear Sir or Madam
In accordance with the Whistleblower Protection Act of 14 June 2024 (Journal of Laws 2024, item 928), which implements the Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019 on the protection of persons who report breaches of Union law (OJ EU L 305 of 26 November 2019, p. 17), we hereby inform you that under Ordinance No. 13/2024 of 17 September 2024 (following consultations with the trade unions at CK ZAMEK), the following Internal Reporting Procedure for Violations of the Law and Follow-Up Actions is in force at ZAMEK Culture Centre.
1. ZAMEK Culture Centre in Poznań recognizes the utmost importance of establishing internal procedures enabling one to report violations of the law safely and confidentially.
2. In accordance with the provisions of the Act and the aforementioned Procedure, a Whistleblower is a natural person who reports or publicly discloses information concerning a violation of the law obtained in the context of their work at CK ZAMEK. The Whistleblower Protection Act enumerates examples of professional categories to which the work-related context applies. These include, in particular:
a) employee;
b) former employee;
c) persons performing work on a basis other than an employment relationship, for instance under a civil law contract;
d) entrepreneur;
e) intern, volunteer, apprentice.
3. A violation of the law is understood to mean an act or omission that is unlawful or intended to circumvent the law where it concerns:
1) corruption;
2) public procurement;
3) financial services, products, and markets;
4) prevention of money laundering and terrorism financing;
5) product safety and their compliance;
6) transport safety;
7) environmental protection;
8) radiation protection and nuclear safety;
9) food and feed safety;
10) animal health and welfare;
11) public health;
12) consumer protection;
13) privacy and personal data protection;
14) security of network and information systems;
15) financial interests of the State Treasury of the Republic of Poland, local government bodies and the European Union;
16) the internal market of the European Union, including competition rules, state aid and taxation of legal persons;
17) constitutional freedoms as well as human and civil rights, particularly where it concerns relations between individuals and public authorities that are unrelated to the domains listed in subsections 1-16.
3. CK ZAMEK will only accept written reports submitted in an electronic form, i.e. via an e-mail sent to the dedicated address: sygnalista.zgloszenie@ckzamek.pl
4. CK ZAMEK does not accept anonymous reports of violations of the law.
5. A report of a violation should include, in particular:
1) the details of the person who reports the violation, including contact details;
2) the date and place of the violation;
3) a detailed description of the reported violation;
4) the details of the person or persons to whom the report of the violation pertains;
5) if applicable, the details of other persons who possess knowledge of the violation (witnesses, affected persons, etc.), including their contact details;
6) if applicable, details of persons associated with the Whistleblower;
7) statement of evidence which confirms the violation of laws or internal procedures (any documents in any format), or additional information which substantiates the occurrence of the violation, justifies the suspicion thereof, or facilitates the clarification of the report.
6. The personal data of the Whistleblower and other data enabling their identity to be determined shall not be disclosed unless the Whistleblower expressly consents to such disclosure.
7. CK ZAMEK shall prevent access to the information in the report and shall ensure confidentiality of the identity of the Whistleblower and the Person to whom the report pertains. Any information that may be used to identify such persons, directly or indirectly, shall be kept strictly confidential.
8. Within 7 (seven) days of receiving the report, the Report Coordinator shall send the Whistleblower confirmation of having received their report, unless the Whistleblower has not provided an address to which such confirmation may be sent.
9. The person who reports a violation of the law should act in good faith. Submission of a report in bad faith may constitute grounds for liability, including disciplinary liability or liability for loss resulting from the violation of the rights of others or obligations specified in relevant laws, in particular with regard to defamation, violation of personal rights, copyright, personal data protection regulations and the confidentiality obligation, including business secrets.
10. Submission of a report in bad faith is also liable to a fine, restriction of personal liberty or imprisonment for up to two years.
11. A person who has suffered loss as a result of a deliberate submission of false information by the Whistleblower is entitled to compensation or damages from the Whistleblower who has acted in bad faith.
12. The full text of the “Procedure” is available at the headquarters of ZAMEK Culture Centre, from the institution’s Front Desk, Room 134.
