Information on the terms and conditions for filing reports under ZZLPSPOIN

INFORMATION REGARDING THE CONDITIONS AND PROCEDURES FOR SUBMITTING WHISTLEBLOWERS UNDER THE LAW FOR THE PROTECTION OF PERSONS WHO MAKE WHISTLEBLOWERS OR PUBLICLY DISCLOSE INFORMATION ABOUT VIOLATIONS

PFC Ludogorets 1945 carries out open and responsible management and conducts its business, observing the highest standards, in order to protect the interests of its workers, employees and business partners, giving the opportunity to workers, employees and third parties to whom it is provided protection under applicable law to report violations, including potential violations, at the earliest possible stage without fear of retaliation.

Ways of internal reporting of violations

Pursuant to the Law on the Protection of Persons Submitting Whistleblowers or Publicly Disclosing Information on Violations, PFC Ludogorets 1945 has created the following channels for internal reporting of violations of Bulgarian legislation or of acts of the European Union, information about which is available to them became known during or on the occasion of the performance of their work or official duties, or in another work context:

• to the following email address: whistleblowing@ludogorets.com
• for employees with e-mail - on the organization's official e-mail;
• for others – by e-mail signed with a Qualified Electronic Signature (QES);
• a personal meeting with one or some of the members of the Commission for consideration of signals of violations, which can be arranged in writing by e-mail or verbally, in a conversation with one or some of the members of the Commission.

Reporting violations

Reports are submitted in writing or orally to the Commission for Reviewing Reports of Violations. Any kind of sources of information supporting the statements made in it and/or reference to documents, including the indication of data on persons who could confirm the reported data or provide additional information, can be attached to each signal.

Written reports are submitted by filling in a form according to a model approved by the central body for external reporting - the Commission for the Protection of Personal Data, which contains at least the following data:

1. the sender's three names, address and phone number, as well as an email address, if any;
2. the names of the person against whom the report is filed and his workplace, if the report is filed against specific person and they are known;
3. specific details of a violation or of a real danger that it will be committed, place and period of the violation, if it was committed, a description of the act or the situation and other circumstances, as far as these are known to the reporting person;
4. date of submission of the signal;
5. signature, electronic signature, or other identification of the sender.

Verbal whistle-blowing is possible through a personal meeting (requested by the whistleblower) with the competent person(s) within a suitable time agreed between them. The verbal report is documented by the completion of the form by one of the members of the Whistleblowing Committee, who offers the whistleblower to sign it if he wishes.

Within 7 (seven) days of receiving the signal, a confirmation is sent to the reporting person. The submitted reports are considered by the Commission for Reports of Violations of PFC Ludogorets 1945. Feedback is provided to the whistleblower about the actions taken within a period of no longer than 3 (three) months after the confirmation of receipt of the signal or, if no confirmation was sent to the whistleblower, after the expiration of no more than 3 (three) months, starting from the expiration of the 7-day period. In order to clarify the facts and/or circumstances described in the report, additional information and explanations may be required from the reporting person, as well as from any third party who may in some way be connected to the report and/or provide more information on the case.

In view of the possibility of quickly preventing a violation or removing the consequences of such a violation, the signal should be submitted as a priority through an internal reporting channel. PFC Ludogorets 1945 encourages the reporting of violations through internal channels. PFC Ludogorets 1945 guarantees whistleblowers that no retaliatory actions will be taken if they had good reason to believe that the information about the violations in the whistleblowers was correct at the time of their submission.

No proceedings are initiated, and no inspection is carried out for:

1. anonymous signals;
2. reports relating to violations committed more than two years ago.

If a given report does not meet the requirements of the Law on the Protection of Persons Submitting Reports or Publicly Disclosing Information on Violations and the Policy of PFC Ludogorets 1945 for Reporting Violations, the reporting person is sent a notice to remedy the irregularities within 7 days of receiving the signal. If the irregularities are not corrected within this period, the report together with the attachments to it is returned to the reporting person.

Each signal is checked for its credibility. Reports that do not fall within the scope of the Law on the Protection of Persons Submitting Reports or Publicly Disclosing Information on Violations and the Policy of PFC Ludogorets 1945 for reporting violations, and the content of which does not give grounds to are assumed to be plausible. Reports that contain patently false or misleading statements of fact will be returned with instructions to the sender to correct the statements and the sender's responsibility for persuasion.