Whistleblower Policy

This procedure (hereinafter referred to as the "Procedure") lays down, in particular:



The procedures and channels for whistleblowers for reporting breaches of law, pursuant to the Act of 14 June 2024 on the Protection of Whistleblowers;

1. The procedure for receiving whistleblower reports and their assessment, as well as the rules for taking follow-up actions.
2. The rules and procedure for reporting other irregularities, as well as the process for their receipt and assessment.
3. Entities authorised to receive the reports referred to in paragraphs 2 and 3 above and to undertake follow-up actions, as well as the rules for selecting their members.

Whenever the Procedure refers to:

1. Monterail – it must be understood as Monterail, a limited liability company with its registered office in Wroclaw;


2. follow-up actions – it must be understood us any action taken by Monterail to assess the accuracy of the information provided in the report and to address the breach of law reported, particularly through investigative proceedings, initiating inspections or administrative procedures, filing charges, actions taken to recover financial resources or the closure of the procedure conducted under the internal reporting and taking follow-up actions or the external reporting and taking follow-up actions.

3. retaliatory action – it must be understood as any direct or indirect action or omission in a work- related context, which is caused by the reporting or public disclosure, and which violates or may violate the whistleblower’s rights or causes or may cause unjust harm to the whistleblower, including unjustified initiation of proceedings against the whistleblower.

4. 
information on a breach of law – it must be understood as information, including a reasonable suspicion of an actual or potential breach of law, that has occurred or is likely to occur within Monterail, provided that the whistleblower was involved in the recruitment process or other negotiations preceding the conclusion of a contract with Monterail, is or was employed by Monterail, or if the whistleblower maintains or has maintained contact with Monterail in a work- related context, or information concerning an attempt to conceal such a breach of law.

5. feedback – it must be understood as information provided to the whistleblower about the planned or undertaken follow-up actions and the reasons for such actions.

6. work-related context – it must be understood as past, present or future activities related to performing work under an employment contract or another legal relationship constituting the basis for providing work or services (including B2B) or holding a position at or on behalf of Monterail, within which information about a breach of law was obtained and there is a possibility of experiencing retaliation.


7. public authority – it must be understood as central and national government administrative bodies, regional government administrative bodies, local government authorities, other state bodies, and other entities performing public administration tasks by virtue of law, which are competent to undertake follow-up actions.


8. person concerned by the report – it must be understood as a natural person, a legal entity or an organisational unit without legal personality that is granted legal capacity by the law, identified in the report or public disclosure as the person who committed the breach of law or as a person connected to the person who committed the breach of law.


9. person assisting in making a report – it must be understood as a natural person who helps the whistleblower in making a report or public disclosure related to work and whose assistance should remain confidential.


10. person connected to the whistleblower – it must be understood as a natural person who may experience retaliatory actions, including a contractual partner or a close relative of the whistleblower, such as a spouse, ancestor, descendant, sibling, relative by marriage in the same line or degree, an adopted person and their spouse or a person living together with the whistleblower.


11. person reporting irregularities – it must be understood as an employee or contractual partner of Monterail who makes a report of irregularities pursuant to the procedures set forth in Chapter IV of this Procedure.


12. legal proceedings – it must be understood as proceedings conducted under the provisions of applicable law, particularly criminal, civil, administrative, disciplinary proceedings, or those related to breaches of public finance discipline, as well as proceedings based on internal regulations issued to implement generally applicable law, including anti-mobbing regulations.


13. whistleblower – it must be understood as a natural person who reports or publicly discloses information about a breach of law obtained in the context of work with Monterail, including an employee, a temporary worker, a person performing work based on a contract other than an employment contract such as civil contract (i.e.B2B), an entrepreneur, a commercial proxy, a shareholder or partner, a member of the governing body of a legal person or an entity without legal personality, a person working under the supervision and direction of a contractor, a subcontractor or supplier, an intern, a volunteer or a trainee. The term also applies to a natural person in the aforementioned categories if they report or publicly disclose information about a breach of law obtained in the context of work before establishing an employment or other legal relationship constituting the basis for providing work or services or holding a position at or on behalf of Monterail or even after such a relationship has ended.


14. public disclosure – it must be understood as making information about a breach of law available to the public.


15. act – it must be understood as the Act of 14 June 2024 on the Protection of Whistleblowers.


16. report – it must be understood as an oral or written internal report or external report to which the provisions of the law apply.


17. irregularity report – must be understood as the communication to Monterail of information regarding an irregularity


18. internal reports – it must be understood as communication to Monterail of information regarding a breach of law, to which the provisions of the Act apply.


19. external reports – it must be understood as oral or written communication to the Ombudsman or a public authority of information regarding a breach of law, to which the provisions of the Act apply.


20. irregularities – it must be understood as any type of conflicts and misunderstandings between employees or contractual partners of Monterail, or where an employee or contractual partner is involved with a client or contractor of Monterail, undesirable behaviour by a superior or another employee or contractual partner, or by a client or contractor of Monterail, which may constitute a breach of law but is not specifically covered by the provisions of the Act.


21. employee – means a natural person employed under an employment contract.


22. contractual partner – it must be understood as a natural person employed under a contract other than an employment contract (i.e., a civil contract), cooperating with the entity on an exclusive basis or holding a distinct position in the organisational structure of that entity, including, in particular, those under contracts for specific tasks or services, as well as persons operating as sole proprietors.

1. The provisions of this Chapter II shall only apply to internal reports.

2. In the manner described in this Chapter II, a whistleblower may report information on a breach of law related to:

   1. corruption;

   2. public procurement;

   3. financial services, products and markets;

   4. anti-money laundering and counter-terrorist financing;

   5. product safety and compliance with requirements;

   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. network and information system security;

   15. financial interests of the State Treasury of the Republic of Poland, local authorities and the European Union;

   16. internal market of the European Union, including public law competition rules, state aid and corporate taxation;

   17. constitutional freedoms and human and citizen rights – occurring in relations between persons and public authorities and not related to the areas listed above.

1. An internal report may be submitted in writing (electronically) or orally, using one of the following reporting channels:

   1. orally – through an online meeting, i.e. using remote communication tools employed by Monterail, pursuant to the rules set out in paragraph 2 below;

   2. orally – through a direct meeting, pursuant to the rules set out in paragraph 3 below;

   3. in writing – via email to the address: whistleblower@monterail.com;

   4. in writing – online using the reporting form provided by Monterail.

2. Upon the whistleblower's request, internal reports may be made orally during an online meeting organised within 14 days from the receipt of such request. If the internal report is made using tools that support recording, it is documented, with the whistleblower's consent, either as a searchable recorded conversation or as a complete and accurate transcription of the conversation prepared by a member of the Trust Team receiving the internal report. If the report is made using tools that do not support recording, it is documented in the form of minutes of the conversation, reflecting its exact course, prepared by a member of the Trust Team receiving the internal report.

3. Upon the whistleblower's request, an internal report may be made during a direct meeting organised within 14 days from the receipt of such request. In this case, with the whistleblower's consent, the internal report is documented in the form of:

   1. a searchable recorded conversation or

   2. minutes of the meeting, reflecting its exact course, prepared by a member of the Trust Team receiving the internal report.

4. The whistleblower may review, correct and approve the transcription or minutes of the meeting referred to in paragraphs 2 and 3 above by signing them.

5. When making an internal report or requesting a meeting as referred to in paragraphs 2 or 3 above, the whistleblower may specify a particular member of the Trust Team to whom they wish to entrust the receipt of the internal report.

6. The whistleblower may also make an internal report anonymously using the channels indicated in paragraphs 1(c) and 1(d) of this paragraph.

To ensure the efficient handling of internal report and taking effective follow-up actions, it is recommended that internal report shall include, in particular:

1. personal data of person concerned by the report;

2. detailed information on a breach of law (i.e. the nature of the breach, legal basis, time, place, circumstances, witnesses);

3. whistleblower's personal data, including correspondence address or email address (unless the internal report is made anonymously – in which case providing these data is optional and entirely up to the whistleblower);

4. indication of evidence supporting the breach of law (any documents in any format) or additional information that substantiates the occurrence of the breach or justifies its suspicion or could assist in clarifying the internal report.

1. Internal reports are received by the Trust Team. With the exceptions referred in § 4(5) of the Procedure, each internal report is received by at least one member of the Trust Team in accordance with their current workload resulting from ongoing duties.

2. Upon receipt of an internal report, the Trust Team member referred to in paragraph 1 performs a preliminary assessment, particularly checking whether it falls under the scope of the procedure described in this Chapter II and then undertakes one of the actions set out in paragraph 4 below.

3. If the internal report contains insufficient information to be properly classified, the Trust Team member referred to in paragraph 1, if possible, requests the whistleblower to provide additional information.

4. Based on the results of the preliminary assessment of the internal report, the person conducting it takes one of the following actions:

   1. in the circumstances referred to in paragraph 5 below, decides to cease the investigative proceedings,

   2. if the report concerns an irregularity but was made under the procedure for internal reports, it will be accepted for consideration and processed pursuant to the rules set out in Chapter IV of the Procedure;

   3. in other cases, i.e. if it is determined that the received information constitutes an internal report – informs Monterail (i.e. its management) of the need to appoint the committee referred to in § 7(1) of the Procedure and forwards the internal report to this committee to initiate investigative proceedings and notifies the whistleblower of the acceptance of the internal report pursuant to paragraph 6 below.

5. Investigative proceedings are not initiated if, as a result of the preliminary assessment, it is determined that:

   1. the internal report does not contain information sufficient to initiate and conduct investigative proceedings and despite requesting additional information from the whistleblower, if possible, it was not supplemented with such information;

   2. the internal report is clearly unfounded, meaning the circumstances described clearly indicate that there was no breach or a threat of such breach of law referred to in § 3(2) of the Procedure.

6. The Trust Team member receiving the internal report will notify the whistleblower or the person reporting an irregularity of the decision referred to in paragraph 4 above within 7 days from the receipt of the internal report or irregularity report, respectively, unless the whistleblower or the person reporting an irregularity did not provide a contact address to which the confirmation should be sent (this particularly applies to anonymous reports).

1. The internal report is handled by a committee appointed by Monterail on each occasion, consisting of at least 3 members selected from the Trust Team and the People Team. The member designated by Monterail serves as the chairman of the committee.

2. If the proper handling of the internal report requires specialised knowledge not possessed by any member of the Trust Team or the People Team, the committee may also include an employee or contractual partner of Monterail with the necessary expertise. Monterail selects the person for the committee, with the person's consent provided at least in a documentary form (i.e. via email) and with a statement guaranteeing and committing the person to impartiality.

3. The composition of the committee handling the internal report may also be supplemented with employees or contractual partners of Monterail who are not part of the Trust Team or the People Team in situations where, due to objective reasons, it is impossible to select at least 3 members from among them (i.e. due to reduced staffing, vacations, illness or inability to conduct by- elections in a timely manner to handle the internal report in accordance with the act, etc.), Monterail selects the person for the committee, with the individual's consent provided at least in a documentary form (i.e. via email) and with a statement guaranteeing and committing the person to impartiality.

4. A legal adviser or attorney-at-law providing legal advice to Monterail participates in the committee's work with an advisory vote. The committee may also seek support from other external advisors at any stage of handling and processing the internal report.

5. A member of the committee handling a particular internal report cannot be:

   1. the whistleblower, the person concerned by the internal report, a person assisting in making the report or a person connected to the whistleblower;

   2. the direct supervisor of the whistleblower or a person directly subordinate to the whistleblower;

   3. the spouse, relative, or in-law up to the second degree of the whistleblower or the person concerned by the report or anyone in such a legal or factual relationship with those persons that might raise reasonable doubts about their impartiality.

6. If a committee member believes that circumstances exist that could affect their impartiality, they should recuse themselves from the case and inform the other committee members of this fact.

7. In the case referred to in paragraph 6 above:

   1. if necessary and feasible, actions taken with the participation of the recused person must be repeated;

   2. Monterail may appoint a new member who meets the requirements of impartiality and independence.

1. The committee conducts the investigative proceeding with due diligence, impartially and reliably.

2. The purpose of the investigative proceeding is to gather all possible information and evidence regarding the case, assess them, and, where possible, confirm or rule out the breach of law referred to in the internal report, as well as determine the extent of any potential damage.

3. The investigative proceeding should commence promptly, and no later than 30 days from the receipt of the internal report.

4. As part of the investigative proceeding, the committee is specifically authorised to:

   1. access both paper and electronic official correspondence and documentation necessary to clarify the matter;

   2. make copies of documents;

   3. collect statements;

   4. hear witnesses;

   5. hear the person concerned by the report.

5. Decisions of the committee are made by a simple majority of votes with the presence of at least half of the committee members. Each committee member has one vote. In the event of a tie, the chairman’s vote is decisive.

6. Subject to the provisions of generally applicable law, organisational units of Monterail are required to cooperate with the committee during the investigative proceeding, including providing explanations or statements, making and providing copies of documents and preparing analyses

of issues (i.e. summaries or data extracts) in the formats and within the time limits specified by the committee.

1. Any person summoned by the committee should appear at the appointed time and provide explanations regarding the matter under the investigative proceeding to the best of their knowledge.

1. Upon concluding the investigative proceeding, the committee issues an opinion on the validity of the internal report. The validity of the internal report is determined by a vote conducted pursuant to the rules set out in § 8 (5) of the Procedure.

2. If the internal report is found to be valid, the committee will issue recommendations for corrective and preventive actions aimed at eliminating similar breaches in the future.

3. Recommendations described in paragraph 2 above that involve or may involve financial expenditure by Monterail or require actions outside Monterail (i.e. external actions) must receive prior approval from Monterail (i.e. its management).

4. Corrective or preventive actions may include, but are not limited to:

   1. implementing organisational or staffing changes;

   2. revising internal regulations;

   3. conducting training sessions or informational campaigns;

   4. applying sanctions in accordance with the Monterail’s work regulations, the Labour Code, civil law agreements or the Civil Code;

   5. initiating legal proceedings or submitting relevant applications or other measures to commence legal action;

   6. notifying appropriate law enforcement agencies (i.e. the Central Anti-Corruption Bureau, Police, Prosecutor’s Office).

5. Organisational units of Monterail are required to notify the committee of their intention to implement or not implement the recommendations provided by the committee and subsequently report on the implementation or non-implementation of these recommendations along with justification. If an organisational unit disagrees with a committee recommendation, the decision on whether to implement the recommendation will be made by Monterail (i.e. its management).

6. The committee may terminate the investigative proceeding if:

   1. the information provided in the internal report is insufficient and additional necessary information from the whistleblower could not be obtained;

   2. it is determined that the internal report was malicious or is not valid.

7. All actions taken by the committee are documented in writing or electronically, particularly in the form of an official note. A protocol of the investigative proceeding is prepared and signed by the committee members, with the format described in Annex 4 to this Procedure.

1. The committee will provide feedback to the whistleblower promptly, within a maximum of 3 months from the date of confirmation of receipt of the internal report or, if no confirmation is provided, within 3 months from the expiration of 7 days after the internal report is made, unless the whistleblower did not provide a contact address for receiving feedback.

2. The feedback will include, in particular, information on whether or not a breach of law referred to in the internal report was identified and details of planned or undertaken follow-up actions and the reasons for such actions. A template for the feedback is provided in Annex 2 to this Procedure.

1. Each received internal report must be registered in the internal report register.

2. Monterail authorises the Trust Team to maintain the internal report register. The entry is made by a member of the Trust Team who is part of the committee reviewing the specific internal report, as referred to in § 7 (1) of the Procedure. If no such member is available, the entry is made by the Trust Team member who received the internal report.

3. The internal report register includes:

   1. internal report number;

   2. subject of the breach of the law;

   3. personal data of the whistleblower and the person concerned by the report, necessary for identifying these persons;

   4. contact address of the whistleblower;

   5. date of the internal report submission;

   6. information on the follow-up actions taken;

   7. date of conclusion of the matter.

4. All documentation collected during the investigative proceeding, including minutes referred to in

§ 9 (7) of the Procedure, is retained for a period of 3 years after the end of the calendar year in which follow-up actions related to the accepted internal report were completed or the proceedings initiated by those actions were concluded.

1. The documentation referred to in paragraph 4 above must be stored in a manner that prevents unauthorised access and complies with applicable data protection laws. Sensitive personal data requires special protection.

2. The internal report register is maintained in a manner that ensures the confidentiality of the whistleblower’s data. A Trust Team member who is also the subject of the report should not have access to the part of the register that concerns their own internal report.

1. Monterail ensures adequate measures to protect the confidentiality of the whistleblower's identity, the person concerned by the report and other persons referred to in the internal report or whose personal data was obtained during the investigative proceeding. This includes persons assisting in making the report, witnesses to the breach and persons connected to the whistleblower.

2. Confidentiality also extends to information obtained during the handling of the internal report that could directly or indirectly identify the persons specified in paragraph 1 above.

3. Access to personal data and information specified in the internal report is restricted to persons authorised to process such data, to the extent necessary for performing tasks related to handling internal reports and follow-up actions.

4. Any data that allows for the identification of the whistleblower can only be disclosed with the whistleblower’s prior explicit consent.

5. Monterail or its authorized units or persons, including members of the Trust Team and the committee, may disclose whistleblower data without explicit consent if such disclosure is a necessary and proportionate obligation under the law in connection with investigation conducted by public authorities or preparatory or court proceedings, including to guarantee the right to defence of the person concerned by the report.

6. A breach of confidentiality obligations may result in appropriate proceedings against the individual who committed the breach.

1. A whistleblower is protected from retaliatory actions from the moment the report is made or publicly disclosed, provided that the whistleblower had reasonable grounds to believe that the information reported or disclosed was true at the time of the report or disclosure and constituted information on a breach of law.

2. No retaliatory actions may be taken against the whistleblower, consisting in particular of:

   1. refusal to establish an employment relationship;

   2. employment termination or dismissal without notice;

   3. failure to conclude a fixed-term or indefinite-term employment contract after termination of a probationary contract or failure to conclude a subsequent fixed-term or indefinite-term employment contract if the whistleblower had a reasonable expectation of such a contract;

   4. reduction of salary;

   5. suspension of promotion or exclusion from promotion;

   6. exclusion from or reduction of non-salary employment benefits;

   7. transfer to a lower position;

   8. suspension from employee or professional duties;

   9. assignment of the whistleblower's duties to another employee;

   10. unfavourable change in work location or schedule;

   11. negative performance evaluation or unfavourable work opinion;

   12. imposition or application of disciplinary measures, including financial penalties or similar measures;

   13. coercion, intimidation or exclusion;

   14. mobbing;

   15. discrimination;

   16. unfavourable or unjust treatment;

   17. suspension of or exclusion from professional development training;

   18. unjustified referral for medical examinations, including psychiatric examinations, unless allowed by separate regulations;

   19. actions aimed at hindering future employment in particular sector or industry based on informal or formal sectoral or industry agreements;

   20. procuring financial loss, including economic loss or loss of income;

   21. causing other immaterial damage, including infringement of personality rights, especially the whistleblower's reputation.

3. Attempts or threats to apply any of the measures listed in paragraph 2 are also considered retaliatory actions.

4. A whistleblower subjected to retaliatory actions is entitled to compensatory damages of not less than the average monthly wage in the national economy for the previous year, as announced for pension purposes in the Official Journal of the Republic of Poland "Monitor Polski" by the President of the Central Statistical Office or to compensation for damages.

5. Breach of the prohibition against retaliatory actions will result in Monterail initiating appropriate proceedings or taking relevant actions against the individual responsible for such a breach.

6. Making false or malicious reports of breaches or using reporting to harm other persons associated with Monterail is absolutely unacceptable and should not enjoy legal protection. Such actions may lead to consequences described in § 16 of the Procedure.

7. Whistleblowers are required to submit internal reports only in the manner and form specified in this chapter II of the Procedure. Internal reports made in breach of this Procedure or extending beyond the scope covered by this Procedure or the law will not be processed pursuant to the rules in this chapter, and the person submitting such reports will not be entitled to the protections described in § 13 – § 15 of the Procedure.

1. If work or services are, have been or will be provided based on a legal relationship other than an employment contract, which constitutes the basis for providing work, services, holding a position or serving, the provisions of § 13 (1), (2), and (3) above shall apply accordingly, provided that the nature of the work, services, position or service does not exclude such actions being taken against the whistleblower.

2. If work or services are provided based on a legal relationship other than an employment contract, making a report or public disclosure cannot be the basis for retaliatory actions or attempts or threats of retaliatory actions, including, but not limited to:

   1. termination of a contract involving the whistleblower, especially concerning the sale or supply of goods or provision of services, withdrawal from such a contract or its termination without notice;

   2. imposing an obligation or refusal to grant, limit or revoke a right, including concessions, permits or benefits.

3. The provisions of § 13 (4) – (7) shall apply directly.

1. The provisions of § 13 and § 14 of this chapter apply accordingly to person assisting in making a report and to person connected to the whistleblower.

2. The provisions of § 13 and § 14 of this chapter also apply accordingly to legal entities or other organisational units that assist the whistleblower or are connected with them, including entities owned by or employing the whistleblower.

1. Submitting a malicious report may result in liability, including disciplinary measure or damages for injury caused by breaching the rights of others or legal obligations, particularly regarding defamation, infringement of personality rights, copyright laws, data protection provisions and confidentiality, including trade secrets.

2. A person making a report or public disclosure knowing that no breach of law occurred is subject to a fine, restriction of freedom or imprisonment for up to 2 years.

3. A person who suffers injury due to a whistleblower's deliberate submission of false information has the right to compensatory damages or redress from the whistleblower who made the malicious report.

1. If the whistleblower believes there is a risk of retaliatory actions or if required by the provisions of generally applicable law, they are also entitled to use external reporting channels to report breaches. In this regard, designated public authorities are responsible for receiving external reports.

2. The Trust Team is responsible for providing information to any interested parties, including whistleblowers, regarding the procedures for making external reports to the Polish Ombudsman, public authorities, and, where applicable, to institutions, bodies or entities of the European Union. This information is also available on a shared drive accessible to Monterail’s employees and contractual partners.

3. The Trust Team will promptly provide and update the information referred to in paragraph 2 above as determined by the relevant public authority.

1. Irregularity reports in accordance with the procedures outlined in this Chapter IV may only be made by employees and contractual partners of Monterail. The provisions of the act do not apply to irregularity reports (i.e. irregularities other than breaches of law, to which the provisions of the act apply).

2. Irregularity report may be done through one of the following methods, chosen by the person reporting the irregularity:

   1. orally – during a meeting with their supervisor (either in person or online using any communication platform used by Monterail, i.e. Slack);

   2. orally – during a meeting with the Trust Team (either in person or online using any communication platform used by Monterail, i.e. Slack);

   3. in writing – via email: trust-team@monterail.com

3. In the case referred to in paragraph 2(b) above, the irregularity report is received by at least one member of the Trust Team, based on their current workload from ongoing professional duties. The person submitting irregularity report may indicate a specific Trust Team member to whom they wish to report the irregularity during the meeting referred to in the previous sentence.

4. Minutes of the meeting with the person submitting irregularity report are drawn up in electronic form.

5. The irregularity report should include at least the following:

   1. full name and job position of the person reporting the irregularity or a description of their role in the Monterail’s organisational structure;

   2. full name and job position of the person to whom the report refers (i.e. whose undesirable behaviour is being reported) or a description of their role in the Monterail’s organisational structure;

   3. description of the irregularity;

   4. contact details of the person reporting the irregularity (i.e. email, phone number).

6. In the case of submitting irregularity report to a supervisor, the supervisor prepares the minutes referred to in paragraph 4 and then forwards it to the Trust Team via email: trust- team@monterail.com without undue delay, but no later than within 2 working days from receiving the report of the irregularity.

1. The Trust Team acknowledges receipt of the irregularity report by sending acknowledgment message to the reporting person within 7 days of receipt.

2. The irregularity report is assessed by at least 2 members of the Trust Team, appointed by the Trust Team pursuant to their current workload, provided that if the report concerns a member of the Trust Team, that member is excluded from its assessment.

3. The irregularity report is assessed with due diligence, respecting the confidentiality of the reporting person’s identity, the person concerned by the report and any information obtained in the course of or in connection with the irregularity report.

4. The irregularity report is assessed without undue delay, generally within 5 working days from the date of sending the acknowledgment of receipt to the reporting person. In specific cases, such as those justified by the complexity of the matter or the need for investigation, the timeframe for assessing the irregularity report may be extended to 14 working days. The Trust Team will, where possible, inform the reporting person of the extension of the assessment period.

5. The Trust Team takes necessary steps to verify the validity of the irregularity report, including direct contact with the reporting person or the person concerned by the irregularity report, requesting explanations from persons designated by the Trust Team and reviewing relevant documentation.

6. Upon completing the assessment of the irregularity report, the Trust Team will provide the reporting person with information, particularly including recommendations regarding further action on the matter, such as proposing mediation if needed or describing planned or implemented measures to address the situation outlined in the irregularity report.

In cases where, at the stage of receiving information about a potential irregularity as defined in Chapter IV or during the assessment of an irregularity report, it is determined that the circumstances of the case (including, in particular, its subject matter) indicate that it should be handled and assessed pursuant to the internal reporting rules outlined in Chapter II of the Procedure, the person receiving the irregularity report or the members of the Trust Team assessing the irregularity report shall inform the reporting person accordingly. This information should be communicated without undue delay. The report will be further processed as an internal report. In the case referred to in this paragraph, if the reporting of irregularity was made directly to the immediate superior, such a report shall be promptly forwarded to Monterail (i.e. its management) for the appointment of a committee.

1. The Trust Team consists of:

   1. an arbitrary number of representatives from the People Team, selected among themselves based on rules they establish, including through voting, nomination and acceptance of candidates etc., and

   2. persons elected by the employees and contractual partners of Monterail, through elections organised pursuant to the subsequent provisions.

2. The elections for the Trust Team members, as referred to in paragraph 1(b) above, will be universal, equal and direct. The announcement of the election date and detailed rules will be communicated to Monterail’s employees and contractual partners within reasonable time.

3. Trust Team members are appointed for an indefinite term, but not longer than until the end of their respective employment or cooperation agreement with Monterail. Each member of the Trust

Team has the right to resign from membership. A Trust Team member may be removed by a decision of Monterail’s management, with the date indicated in the decision, in the event of a breach of the provisions of this Procedure or if their conduct does not warrant the proper performance of the tasks set forth in the Procedure. In the event of a vacancy in the section of the Trust Team referred to in paragraph 1(b) above, Monterail shall promptly organise by- elections pursuant to the rules set forth in paragraph 2 above.

1. Any changes in the Trust Team members will be communicated to Monterail’s employees and contractual partners immediately after they come into effect.

2. The up-to-date list of Trust Team members is available at Handbook.

3. Trust Team members provide fundamental guarantees regarding the independence in the assessment of internal reports and irregularity reports and are required to keep all data and information obtained during their assessment strictly confidential.

1. All personal data processed in the course of assessing an internal report or a irregularity report are subject to protection. Members of the Trust Team and other persons authorised by Monterail to carry out tasks set forth in the Procedure should be required to keep such data confidential.

2. Only organisational units and persons designated by Monterail to perform tasks under the Procedure are authorised to process the personal data referred to in paragraph 1 above.

3. Rules for processing of personal data referred to in this Procedure are defined by the privacy policy available at Monterail.com site.

1. This Procedure does not distort or hinge in any way the rights of whistleblowers, the persons concerned by the report or the rights of other persons pursuant to the provisions of generally applicable law.

2. Each employee and contractual partner of Monterail will also receive a written or electronic extract of this Procedure, containing basic information about available reporting channels, recommended content of internal reports, rights and obligations, as well as protection of whistleblowers and rules for internal reporting at Monterail.

3. Each new employee and contractual partner of Monterail confirms their familiarity with this Procedure and receipt of the extract of the Procedure, which constitutes Appendix 6, by signing a statement, the model of which constitutes Appendix 5 to this Procedure. This obligation does not apply to employees and contractual partners of Monterail who held their status on the date of the Procedure’s entry into force.

4. To persons applying for employment under a contract of employment or another legal relationship constituting the basis for providing work or services, Monterail provides information about the Procedure at the start of recruitment or negotiations preceding the conclusion of the contract.

5. This Procedure enters into force 7 days after it has been communicated to Monterail’s employees in the manner adopted by Monterail.