Abuse Reporting System

EPDB Nyomtatási Központ Zrt. (hereinafter: the Company), in order to ensure its lawful and prudent operation, operates a Whistleblowing System for the reporting of violations of legislation, organisational integrity and rules of conduct.

The following persons shall be entitled to report wrongdoing: a current or former employee of the Company; a person who is or was in a contractual relationship with the Company; a person seeking to establish a legal relationship with the Company, in respect of whom the procedure for the establishment of such legal relationship has commenced; as well as any person having a legitimate interest deserving protection in making the report or in the remedying or cessation of the conduct forming the subject of the report.

Reports may be submitted through the following channels:

• via the dedicated e-mail address for the submission of reports: complianceosztaly@posta.hu
• by way of an anonymous report sent by post: Magyar Posta Zrt. – Compliance Department, 1540 Budapest;
• by way of a personal hearing, subject to prior arrangement.

Reports of wrongdoing shall be investigated by the Company’s Compliance Department, which shall, where necessary, involve in the investigation the head of the organisational unit required for the examination of the report.

In the case of a non-anonymous report, at the request of the reporting person – with the exception of classified data and data qualifying as business, economic or other confidential information under statutory provisions – the Compliance Department shall inform the reporting person of the outcome of the investigation.

Information regarding the employer-operated Whistleblowing System pursuant to Sections 18–29 of Act XXV of 2023 on Complaints, Public Interest Reports and Rules for Reporting Abuse:

• A report shall be made in good faith; a report made in bad faith may entail legal consequences.
• Data relating to a third party not concerned by the report, which are not necessary for the investigation of the report and which may not be processed under the Act, shall not be used in the course of the investigation.
• Reports may be submitted to the Whistleblowing System in writing or orally by the Company’s employees or external persons, as well as by the person exercising ownership rights and by the members of the Board of Directors and the Supervisory Board.
• The Company shall treat as confidential, at all stages of the investigation, the identity and personal data of the reporting person, the person concerned by the report, and any person having substantive information regarding the matters contained in the report.
• The Company shall send an acknowledgement of receipt of the report to the reporting person within seven days of receipt of a report submitted in writing.
• Where the reporting person submits the report in person – following the provision of information in accordance with the provisions relating to the protection of personal data – a full and accurate written record shall be taken of the statements made, ensuring the opportunity for the reporting person to review, correct and approve it by signature, and a duplicate copy of the written record shall be provided to the reporting person.
• The investigation of a report may be omitted if the report was submitted by an unidentified reporting person or by a person not entitled to submit a report pursuant to Section 20(2) and (3) of Act XXV of 2023 on Complaints, Public Interest Disclosures and Rules Relating to the Reporting of Wrongdoing; or if the report constitutes a repeated report submitted by the same reporting person with content identical to a previous report; or if the prejudice to the public interest or to an overriding private interest would not be proportionate to the restriction of the rights of the natural or legal person concerned by the report resulting from the investigation thereof.
• The reporting person – if identifiable and if the report was not submitted anonymously – and the manager authorised to take measures in relation to the elimination of any irregularities or deficiencies that may have been established shall be informed in writing of the outcome of the investigation (including the measures taken or planned) or of the decision not to conduct an investigation and the reasons therefor. Written notification may be dispensed with if the reporting person has been informed orally of the outcome of the investigation or of the decision not to conduct an investigation and has acknowledged the same.
• No adverse discrimination, retaliatory measure or sanction may be applied against a person who has made a report in good faith and lawfully, or against a person connected with such reporting person (in particular a family member, colleague or a person who has provided assistance to the reporting person in making the report), and such person shall not be held liable for having made a lawful report. A person who obstructs or attempts to obstruct the lawful making of a report, or who acts adversely against a lawful reporting person or a person connected with such reporting person, commits a regulatory offence. In the event of a presumed irregularity in connection with the operation of the Whistleblowing System, a request for legal remedy may be submitted to the Office of the Commissioner for Fundamental Rights.
• The person concerned by the report, as well as any person having substantive information regarding the matters contained in the report, shall be informed in detail at the commencement of the investigation of the report, of the report itself, of their rights relating to the protection of their personal data, and of the rules governing the processing of their data. In accordance with the requirement of a fair procedure, it shall be ensured that the person concerned by the report may present their position regarding the report, including through their legal representative, and support it with evidence. In exceptional and duly justified cases, the person concerned by the report may be informed at a later stage if immediate notification would frustrate the investigation of the report.
• The statutory deadline for the investigation shall be 30 days from the receipt of the report; this deadline may be departed from only in particularly justified cases, provided that the reporting person is simultaneously informed thereof with reasons. The duration of the investigation may be extended to a maximum of three months.