“AS Hotels” EOOD, registered in the Commercial Register and the Register of Non-Profit Legal Entities with UIC /Company number/ 131261782, publishes this Information on the procedure and conditions for submitting signals of violations on the basis of Article 12, paragraph 4 of the Act for the Protection of Persons Reporting or Publicly Disclosing Information on Violations, hereinafter referred to as the “Act”- below the Act, which establishes the procedure for receiving and investigating signals for violations and ensuring the protection of persons in the company who report or publicly disclose information about violations of Bulgarian law or European Union acts that have come to their attention in the course of or in connection with the performance of their employment or official duties or in another work context.

Applicability

This information applies in relation to signals of violations in the following areas:

1. Violations of Bulgarian legislation or EU acts in the field of:

• Public procurement;
• Financial services, products and markets and the prevention of money laundering and terrorist financing;
• Product safety and compliance;
• Transport safety;
• Environmental protection;
• Radiation protection and nuclear safety;
• Food and fodder safety, animal health and humane attitude to them;
• Public Health;
• Consumer protection;
• Protection of personal life and personal data privacy;
• Security of networks and information systems.

  2. Violations affecting the financial interests of the European Union within the meaning of Article 325 of the Treaty on the Functioning of the European Union.

  3. Violations of internal market rules within the meaning of Article 26(2) of the
  of the Treaty on the Functioning of the European Union, including the rules of the European Union and Bulgarian legislation on competition and public benefits.

  4. Violations relating to cross-border tax schemes designed to obtain a tax advantage contrary to the object or purpose of the applicable corporate tax law.

  5. A committed general offence, of which a person has become aware regarding the performance of his work or in the performance of his official duties.

  6. Signals or public disclosure of information on violations of Bulgarian legislation in the field of:

• The rules for the payment of outstanding public state and municipal receivables;
• Labour legislation;
• Legislation relating to the performance of public service.

Channels for reporting signals

Signals shall be submitted in priority via the internal signals reporting channel as indicated in the sections below.

In the event of a reasonable belief that a risk exists for the person reporting the signal, the signal may be reported to the national external reporting authority, the Commission for Personal Data Privacy (CPDP). Information on the procedure and manner for reporting signals regarding the Law you may find on the website of the CPDP: https://www.cpdp.bg

Reporting signals via the internal channel

A signal may be reported in person or by proxy with express written authority

in one of the following ways:

• На електронен адрес: whistleblow@splf.eu;
• At the following address: Sofia city, 2 Biser Str., flat 5, to the attention of: “Person in charge of Law on Protection of Persons Reporting Signals or Publicly Disclosing Information About Violations (LPPRSPDIAV). The letter should be marked as ‘Confidential’;
• In a personal meeting with the person in charge, after arrangement at the contact phone number indicated.

The signal should contain the details of the reporting person, which will not be shared with others except for the purpose of the inspection. A written signal must be signed in person by the reporting person and reported by completing a form according a sample of the Personal Data Privacy Commission (available to download here).

A signal may also be reported in free text, in which case it must contain at least the following information: the three names of the sender, address, telephone number and e-mail address, if available; the names of the person against whom the report is made and his/her place of work, if the report is made against a specific person and he/she is known to you; specific details of the violation or of a real risk of such violation; the place and period of the violation, if such has been committed; a description of the act or situation and other circumstances, to the extent known to the reporting person; the date of the report; and the signature, electronic signature, or other identification of the sender.

An oral report is made by filling in the form provided by the PDPC by the responsible officer, who offers the reporting party to sign it if they wish.

The signal may be accompanied by any sources of information supporting the allegations made and/or by reference to documents, including details of persons who could confirm the information reported or provide additional information.

If the signal does not meet any of the requirements, the person responsible shall send a notice to remedy the irregularities within seven (7) days of receipt of the signal. If the deficiencies are not remedied within that period, the signal and its annexes shall be returned.

Registration of a signal submitted via an internal channel

The signal received through the company’s internal channel is registered in the internal register for signals under the LPPRSPDIAV, together with the unique identification number of the signal issued by the PDPC. The reporting person shall be notified of the registration.

Examination of a signal reported via an internal channel

Signals shall be dealt with under the terms and provisions of LPPRSPDIAV. By reported reasonable signals, i.e. those within the scope of LPPRSPDIAV within 3 (three) months from the registration of the signal, an inspection shall be carried out, in the course of which the appropriate actions shall be taken.

Regarding an ongoing inspection, the responsible person shall have the right to request from
the reporting person as well as from third parties for further information, to hear the person concerned, who in turn has the right to object and to present evidence in defence of his allegations. Where action is required with the assistance of a public authority, the signal may be referred to the PDPC, as the reporting person shall be notified in due time.

No signals are considered if they:

• Are submitted anonymously, unless the person in charge decides to initiate an inspection;
• Relate to violations committed more than two (2) years ago;
• Contain allegations of violations outside the scope of the Act.

Additional information

For more information on the rights and obligations under the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information About Violations you may read the full text of the law via this link. The Frequently Asked Questions section regarding the application of LPPRSPDIAV in the internet page of PDPC is available through this link.