*If you do not want to reveal your identity, you must take into account the fact that, by reporting information anonymously, there is no possibility of being contacted, of being asked for additional data, in which case the investigation may not be started and completed.

Nuclearelectrica treats with attention and seriousness the reporting of problems that may constitute violations of the law, deviations or irregularities.  The main irregularities recommended to be promptly reported refer to: violations of the law in a professional context, non-compliance with the Code of Conduct, non-compliance with policies and procedures, improper aspects regarding financial statements and relations between employees, abuse, discrimination, cases of corruption, theft, cases of money laundering and any inappropriate behavior that could harm the reputation of the company or any attempts to hide all of the above.  The Company assumes that all issues and reports submitted are made in good faith, are genuine and legitimate.

In this sense SNN:

– Encourages employees and third parties to feel confident in discussing issues, questioning them and acting ethically;
– Make available to employees and third parties ways to discuss and obtain feedback on any measures taken as a result;
– It is ensured that employees and third parties receive an answer in relation to the problems raised and that they know how to proceed in the situation where they are not satisfied with the measures taken;
– Reassures employees and third parties that if they raise issues they identify in good faith, they will be protected against any retaliation or victimization.

Recognizing the importance of a clear and up-to-date process regarding both internal reporting and the protection of whistleblowers, SNN has established different communication channels that can be used by employees and third parties to express their complaints and report according to Law 361/2022, after as follows:

1) The reporting form
2) Email addresses: managed by the Compliance Office
3) Office of Compliance

In accordance with the applicable SNN Policies, the reporting management activity regarding the reporting of irregularities strictly respects the confidentiality of the persons who report them and strictly prohibits the application of reprisals against them, including in cases where the investigations do not confirm the issues reported in good faith.

THE LEGAL AND PROCEDURAL FRAMEWORK REGARDING THE REPORTING AND PROTECTION OF PUBLIC INTEREST Whistleblowers

– LAW no.  361 / 2022 on the protection of whistleblowers in the public interest
– Extract from the Nuclearelectrica Procedure regarding the Reporting of irregularities and the protection of whistleblowers in the public interest

FREQUENT QUESTIONS

Who are the people who can make reports?

People who have obtained information about violations of the law, in a professional context, can make reports.  The category of these people includes, at least:

• Workers;
• Persons carrying out an independent activity (within the meaning of art. 49 of the TFEU);
• Shareholders and persons who are part of the administrative, management or supervisory body of an enterprise, including non-executive members of the board of directors, as well as paid or unpaid volunteers and interns;
• Any person working under the supervision and direction of the natural or legal person with whom the contract was concluded, its subcontractors and suppliers.

Also, persons whose employment relationships have not yet begun and who report or publicly disclose information regarding violations of the law obtained during the recruitment process or other pre-contractual negotiations, or if the report of employment or service relationship has ended, as well as persons who report or publicly disclose information regarding violations of the law anonymously.

What is meant by the expression “Violations of the law”?

By violations of the law, we understand facts that consist of an action or inaction that constitute non-compliance with the legal provisions set out in annex no.  2 of Law no.  361/2022, which concern areas such as:
• public procurement;
• financial services, products and markets, 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 privacy and personal data and the security of networks and IT systems.

At the same time, they also concern:
• violations affecting the financial interests of the European Union (as referred to in art. 325 of the Treaty on the Functioning of the European Union and as 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 European Union rules on competition and state aid, as well as violations related to the internal market regarding regarding acts that violate the rules on corporate taxation or mechanisms whose purpose is to obtain a fiscal advantage that goes against the object or purpose of the law applicable to corporate taxation, that represent disciplinary violations, misdemeanors or crimes, or that go against the object or purpose of the law.

What should the report include?

The reporting includes at least the following:
• Name and surname;
• Contact details of the public interest whistleblower;
• The professional context in which the information was obtained;
• The person concerned, if known;
• Description of the act likely to constitute a violation of the law within the public or private entity;
• Evidence in support of reporting;
• Date and signature.
As an exception, reporting that does not include the name, surname, contact details or signature of the whistleblower in the public interest is examined and resolved to the extent that it contains substantial indications of violations of the law.

What are the differences between anonymous reporting and nominal reporting?

A public interest whistleblower can make the report nominally or anonymously.  From a procedural point of view, the main differences between the two reporting methods are:
• Anonymous reporting cannot be improved by further providing solid clues, while reporting that includes the whistleblower’s identifying data can be improved by further communication between the integrity inspector and the public interest whistleblower;
• The person who reports violations of the law anonymously cannot benefit from exemption and protection in accordance with the provisions of Law no.  361/2022;
• The person who reports violations of the law anonymously cannot be notified of the record of the report, the progress made and the way of resolution.