Abuse Reporting System

EPDB Printing Centre Plc. (hereinafter referred to as: “Company”) operates an abuse reporting system for reporting violations of legislation, organisational integrity and rules of conduct in order to operate lawfully and prudently.

Any current or former employee (worker) of the Company, any person who has or has had a contractual relationship with the Company, or is seeking to enter into a contractual relationship with the Company, or any person who has commenced the procedure for the establishment of a legal relationship, and any person is entitled to report abuse, who has a legitimate interest in making the notification or in remedying or putting an end to the conduct which is the subject of the notification. 

You can make a report using the following channels:

• e-mail address dedicated to making notifications: panaszkezeles@epdb.hu 
• the possibility of anonymous notification in the form of a postal letter: EPDB Printing Centre Plc. — Compliance Officer, 1117 Budapest, Budafoki road 107-109. ;
• notification in the form of a personal hearing: by prior arrangement.

Reports of abuse are investigated by the Compliance Officer of the Company, who, if necessary, will involve the head of the organizational unit required to investigate the report.

In the case of a non-anonymous notification, at the request of the notifier, with the exception of classified data or data classified as business, economic or other secret pursuant to a legal provision, the Compliance Officer shall inform the notifier of the outcome of the proceedings.

Information on the Employer Abuse Reporting System under Articles 18-29 of Act XXV of 2023 on Complaints, Whistleblowing and Reporting of Abuse:

• The notification must be made in good faith, a report in bad faith may entail legal consequences.
• Data relating to a third party not involved in the notification, which is not necessary for the investigation of the report and cannot be processed according to the law, will not be used during the investigation.
• Employees of the Company or external persons, the person exercising the right of ownership and members of the Board of Directors and Supervisory Committee may submit a notification in writing or orally to the notification system.
• The identity and personal data of the notifier and the person concerned in the notification and who has relevant information about the information contained in the notification are treated confidentially by the Company at all stages of the investigation.
• The Company shall send the notifier a confirmation of receipt of the notification within 7 days from the date of receipt of the written notification.
• Where the notifier makes his report in person, after being informed in accordance with the rules on the protection of personal data, a complete and accurate record of what has been said shall be drawn up, with the possibility of its verification, rectification or acceptance by signature of the notifier, and a duplicate of the report shall be provided to the notifier.
• The examination of the report may be omitted if the notification is made by an unidentifiable whistleblower or by a person who is not entitled to make the notification in accordance with Section 20 (2) and (3) of Act XXV of 2023 on the Rules Relating to Complaints, Notifications of Public Interest and Reporting of Abuse; or a repeated application by the same applicant with the same content as the previous application; or where the harm to the public interest or overriding reasons relating to the private interest would be disproportionate to the restriction of the rights of the natural or legal person concerned resulting from the examination of the notification.
• The results of the investigation (including the measures taken or planned) or the decision and its reasons for not to carry out the investigation  are communicated in writing to the whistleblower – if the report was identifiable and not anonymous – and to the manager authorised to take action to remedy any irregularities or deficiencies found. Written information may be waived if the notifier has been informed orally of the outcome or omission of the investigation and the notifier has taken note of it.
• A person who makes a lawful report in good faith, or a person associated with him or her (in particular a family member, a colleague or a person who assists the reporting person in making the report), shall not be subject to any discrimination, measure or sanction, and shall not be held liable for having made a lawful report. A person who obstructs or attempts to obstruct the lawful making of a notification and who acts adversely on the lawful notifier or a person connected with him or her is committing an offence. In the event of an alleged irregularity in the operation of the whistleblowing system, a complaint may be lodged with the Office of the Commissioner for Fundamental Rights.
• The person concerned by the notification and the person who has substantial information about the subject matter of the notification must be informed in detail, at the outset of the investigation, about the notification, his or her rights regarding the protection of personal data and the rules applicable to the processing of his or her data. In accordance with the requirement of a fair hearing, it should be ensured that the person concerned by the notification can express his or her views on the notification through his or her legal representative and that he or she can provide evidence in support of those views. The person concerned by the notification may, exceptionally and in justified cases, be informed at a later date if immediate information would prevent the investigation of the report.
• The statutory deadline for the investigation is 30 days from the date of receipt of the notification, which may be waived only in particularly justified cases, with simultaneous reasoned information to the notifier. The duration of the investigation can be extended to a maximum of 90 days.