*If you do not wish to reveal your identity, you should keep in mind that by reporting information anonymously, there is no possibility of being contacted or being asked for additional data, in which case the investigation may not be initiated and completed.

Nuclearelectrica Serv SRL treats with care and seriousness reports regarding issues that may constitute violations of the law, misconduct 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, inappropriate aspects regarding financial situations and employee relations, abuses, discrimination, cases of corruption, theft, cases of money laundering and any inappropriate behavior that could harm the company’s reputation or any attempts to hide all of the above. The company starts from the premise that all issues and reports submitted are made in good faith, are real and legitimate.

In this regard, Nuclearelectrica Serv SRL:

– Encourages employees and third parties to feel confident in discussing emerging issues, questioning them and acting ethically;
– Provide employees and third parties with ways to raise issues and obtain feedback on any measures taken as a result;

– Ensures that employees and third parties receive a response to the issues raised and that they know how to proceed if they are not satisfied with the measures taken;
– Assure 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 those who submit complaints, Nuclearelectrica Serv SRL has established various communication channels that can be used by employees and third parties to express their complaints and report according to Law 361/2022, as follows:

1) Reporting form
2) Email address: speakup@nuclearelectricaserv.ro

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

LEGAL AND PROCEDURAL FRAMEWORK ON REPORTING AND PROTECTION OF WHISTLERS IN THE PUBLIC INTEREST

– LEGEA nr. 361 / 2022 privind protecția avertizorilor în interes public
– Extras din Procedura Nuclearelectrica privind Raportarea neregulilor si protectia avertizorilor in interes public
– Avertizor de integritate Ministerul Energiei
– Procedura operationala privind prevenirea si combaterea hartuirii si a discriminarii la locul de munca

FREQUENTLY ASKED QUESTIONS

Who are the people who can make reports?

Reports may be made by persons who have obtained information regarding violations of the law in a professional context. These persons include, at a minimum:

• 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 undertaking, 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 on violations of the law obtained during the recruitment process or other pre-contractual negotiations or where the employment or service relationship has ended, as well as persons who report or publicly disclose information on violations of the law anonymously, may report violations of the law.

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

By violations of the law, we understand acts consisting 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;
• environmental protection;
• radiological protection and nuclear safety;
• food and feed safety, animal health and welfare;
• public health;
• consumer protection;
• protection of privacy and personal data and the security of networks and information systems.

At the same time, they also concern:

• infringements affecting the financial interests of the European Union (as referred to in Article 325 of the Treaty on the Functioning of the European Union and as detailed in the relevant European Union measures);
• infringements relating to the internal market (referred to in Article 26(2) of the Treaty on the Functioning of the European Union), including infringements of European Union competition and State aid rules, as well as infringements relating to the internal market in relation to acts which infringe corporate tax rules or arrangements the purpose of which is to obtain a tax advantage which is contrary to the object or purpose of the applicable corporate tax law, which constitute disciplinary offences, contraventions or criminal offences, or which are contrary to the object or purpose of the law.

What should the reporting include?

The reporting shall include, at least, the following:

• Name and surname;
• Contact details of the whistleblower in the public interest;
• 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.

By way of exception, the report that does not include the name, surname, contact details or signature of the whistleblower in the public interest shall be examined and resolved to the extent that it contains solid evidence relating to violations of the law.

What are the differences between anonymous reporting and nominal reporting?

A whistleblower can report anonymously or nominally. From a procedural point of view, the main differences between the two reporting methods are:

• Anonymous reporting cannot be improved by subsequent provision of solid evidence, while reporting that includes the whistleblower’s identifying data can be improved by subsequent communication between the integrity officer and the whistleblower in the public interest;
• The person who reports violations of the law anonymously cannot benefit from exoneration 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 registration of the report, the progress made and the method of resolution.