Integrity whistleblowers can report violations of the law that have occurred or are likely to occur, within authorities, public institutions, other legal entities under public law, as well as within legal entities under private law, according to Law no. 361 /2022 regarding the protection of whistleblowers in the public interest.

Violations of the law – facts that consist of an action or inaction that constitute non-compliance with the legal provisions, which concern areas such as: public procurement; financial services, products and markets, as well as the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environment protection; radiological protection and nuclear safety; food and feed safety, animal health and welfare; public health; consumer’s protection; the protection of private life and personal data and the security of computer networks and systems, provided in annex no. 2, violations that affect the financial interests of the European Union, as mentioned in art. 325 of the Treaty on the functioning of the European Union and as are detailed in the relevant measures of the European Union; violations related to the internal market, referred to in art. 26 paragraph (2) of the Treaty on the Functioning of the European Union, including violations of the rules of the European Union regarding competition and state aid, as well as violations related to the internal market regarding the acts that violate the rules regarding the taxation of companies or the mechanisms whose purpose is to obtain a fiscal advantage that contravenes the object or purpose of the applicable law in the matter of corporate taxation, that represent disciplinary violations, misdemeanors or crimes, or that contravene the object or purpose of the law.

The document can be signed electronically and/or holographically, as appropriate.

Methods of reporting:

• Internal – Reporting is done in writing, either on paper physically delivered to the designated person, or in electronic format communicated to the secure email address avertizordeintegritate@ecoind.ro
• External – Reporting to the National Integrity Agency or to public authorities and institutions that, according to special legal provisions, receive and resolve reports regarding violations of the law in their area of competence

Reporting of violations of the law is primarily done through existing internal reporting channels. The public interest whistleblower reporting violations of the law may choose, however, between the internal reporting channel and the external reporting channel. When choosing the reporting channel, the whistleblower in the public interest can take into account aspects such as: the existence of the risk of reprisals, in the case of reporting through internal channels, the impossibility of effectively remedying the violation through internal reporting channels.

The reporting includes, at least, the following: the name and surname, the contact details of the whistleblower in the public interest, the professional context in which the information was obtained, the person concerned, if known, the description of the fact likely to constitute a violation of the law, the evidence in support of the reporting, date and signature, as appropriate.

If you identify violations of the law and wish to file a public interest report:

• download the form from www.incdecoind.ro – Integrity Warning section
• fill in the reporting form with the requested data
• sign the form electronically or holographically, as appropriate
• send the signed form, either by physical delivery to the designated person, or electronically to the secure email address avertizordeintegritate@ecoind.ro

Reference documents:

• Law no. 361/2022
• National anti-corruption strategy 2021-2025

In the case of submitting a PUBLIC INTEREST WARNING, the whistleblower UNDERSTANDS THAT HE CONSENT WITH the processing of personal data, according to EU legislation.

In the capacity of personal data operator, INCD ECOIND applies the provisions regarding

the protection of personal data according to the provisions of Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (Regulation general on data protection), as well as of Law no. 190/2021 on measures to implement Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to data processing with personal nature and regarding the free circulation of this data and repealing Directive 95/46/EC (General Data Protection Regulation) and implements the technical and organizational measures to protect all operations that concern both directly and indirectly the data with personal and which prevent unauthorized or illegal processing, as well as

accidental or illegal data loss. In this sense, in accordance with the provisions contained in recitals 32, 40, and 42 of the preamble of Regulation (EU) 2016/679 as well as in accordance with the provisions of art. 4 paragraph 1) point (11) and art. 6 paragraph 1) letter. (a) of the same act.