Whistleblowing

The whistleblowing process provides an opportunity to report and provide information if activities are observed within the Company that violate the BONO Group Code of Conduct or applicable laws and regulations.

Whistleblowing policy

BONO Group, which comprises SIA “BONO” and its subsidiaries—SIA “BONO ENERGY”, SIA “BONO TRADE”, SIA “BONO LOGISTICS” and SIA “BONO HOUSE” — is committed to conducting business at the highest ethical level, with integrity and professionalism, while taking responsibility for its impact on social and environmental issues.

The Code of Conduct developed by BONO GROUP sets out the principles and standards that all BONO Group employees, managers, and Board members must adhere to in their daily work and interactions with others.

BONO Group expects its suppliers, business partners, employees, managers and Board members to comply with applicable national laws and regulations, as well as with the principles set forth in the Code of Conduct.

If you observe any violations, please report them in accordance with the Whistleblower Policy developed by BONO Group.

Bono Group

Internal whistleblowing

Whistleblower — an individual, who provides information about an alleged violation that may harm the interests of the public, provided that the individual considers it true, and if information about such a violation is acquired as part of one’s work duties or as part of establishing a legal relationship related to work duties, or while participating in a traineeship, and for whom the disclosure of such information could result in adverse consequences. Whistleblowers may include:

  • BONO Group employees,

  • BONO Group trainees,

  • BONO Group’s business partners — individuals (based on a business, partnership, service or other agreement with BONO Group).

Internal whistleblowing is a process in which a whistleblower reports illegal activities in the workplace or activities that violate the principles set forth in BONO Group’s Code of Conduct.

This means that the whistleblower provides information on:

  • a criminal offence,

  • an administrative offence,

  • violations of other legal provisions that contravene the principles set forth in the BONO Group Code of Conduct (acts or omissions),

that harm the interests of BONO Group and the public, particularly regarding the following violations:

  • Inaction, negligence, abuse of official position, or other unlawful conduct on the part of public officials;

  • corruption;

  • fraud;

  • wasteful use of financial resources and property;

  • tax evasion;

  • public health risks;

  • risks to food, environmental, and construction safety;

  • radiation protection and nuclear safety;

  • environmental safety risks, including actions that contribute to climate change;

  • occupational safety hazards;

  • threat to public order;

  • violations of human rights;

  • violations in the areas of public procurement and public-private partnerships;

  • violations in the financial and capital markets sector, including fraud and other illegal activities that threaten the financial interests of the European Union;

  • prevention of money laundering, terrorist financing, and proliferation financing;

  • violations of competition law and regulations governing commercial activity support;

  • violations in the provision of goods and services, including those related to safety and compliance;

  • violations of traffic safety;

  • violations related to the internal market;

  • violations in the field of animal welfare;

  • violations of consumer rights;

  • violations of privacy, personal data protection, and information system security.

When providing information, a whistleblower must be certain that the information provided is true, as the deliberate provision of false information and reporting solely regarding the infringement of personal interests is not considered whistleblowing and the person may be held liable in accordance with the provisions of applicable laws and regulations.

Procedure for internal whistleblowing

For the purpose of internal whistleblowing, BONO Group asks that you use one of the following channels:

Whistleblowing form
The report is reviewed in accordance with the procedures set forth in the relevant laws and regulations.
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