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Whistle-blowing System For the Partners of the Erste Group

 

Erste Bank Hungary Zrt. (hereinafter: the ‘Bank’) operates a whistle-blowing system (hereinafter: the ‘Whistle-blowing System’) subject to Act CLXV of 2013 on Complaints and Reports of Public Interest.The purpose of the Whistle-blowing System is to allow the partners of the Bank (agents and suppliers) to report the violation of legislation and the infringement of public interests and the important interests of the Bank.The rules of conduct protecting the important interests of the Bank are set forth in the Code of Ethics, which is available here (link).

The employees of the Bank, persons in a contractual relationship with the Bank, and persons who have an appreciable lawful interest in making the report or remedying the conduct constituting the subject matter of the report may make reports to the Whistle-blowing System.

When a report is made, the name and address of the Whistle-blower, in the case of a legal entity Whistle-blower, its head office and the name of its statutory representative must be provided.The report may also be made anonymously, but in such a case, the Bank may omit the investigation of the report.

The Whistle-blowers must make a declaration that they make the report in good faith about circumstances known to them or about which they have reasonable grounds to assume that they are true.Your attention is drawn to the fact that in the case of a report made in bad faith, the Bank may take civil law and possibly criminal law steps against the Whistle-blower if it deems necessary.

Procedural and data protection rules governing the investigation of reports:

The Fraud Management Department of the Legal and Compliance Directorate of the Bank will investigate the report, will establish whether any rule has been breached, and will take the steps needed to solve the case.A period of 30 days of receipt of the report is available for its investigation. The Bank may deviate from this deadline only in particularly justified cases, with the simultaneous provision of information to the Whistle-blower, with the exception of reports made anonymously or by an unidentifiable Whistle-blower.The duration of the investigation may not exceed three months.

Pursuant to Act CLXV of 2013 on Complaints and Reports of Public Interest and on the basis of the consent of the Whistle-blower, the Bank may manage the personal data provided in the report of the Whistle-blower and the person(s) concerned in the report in order to investigate the misdemeanour infringing the public interest and/or the important interest of the Bank included in the report, and may forward such data to the body participating in the investigation of the report or competent for conducting proceedings initiated on the basis of the report (e.g. court or investigating authority).The data are forwarded only if it has become obvious that the Whistle-blower provided untrue information of key importance in bad faith, thereby giving rise to a circumstance implying the commission of a criminal offence or misdemeanour, or it appears likely on reasonable grounds that such person has caused third parties to sustain lawful damage or another infringement of rights.The Bank does not publish the personal data of the Whistle-blower without the unambiguous consent of the Whistle-blower.

Please be informed that the Bank will treat your identity and personal data confidentially in all phases of the investigation.The Bank will store the report and the documents associated with it separately and confidentially. Only the dedicated staff of the Fraud Prevention Department may have access to them.

If, on the basis of the investigation, the report is deemed unfounded or no further measure needs to be taken, the Bank will delete the data relating to the report within 60 days following the end of the investigation.If, however, measures are taken on the basis of the investigation, including measures against the Whistle-blower due to legal proceedings, the Bank will manage the data relating to the report up until the final closing of the proceedings instituted on the basis of the report.

The Bank will delete, furthermore, details relating to third parties not actually concerned in the investigation of the report and not required for the investigation of the report from the reporting system.

The Bank informs the Whistle-blower about the result of the investigation and the measures taken.

Please be informed that the Bank may omit the investigation of the report in the following cases:

  • a report that has the same content as a previous report, repeated by the same Whistle-blower, or made after six months of becoming aware of the activity or omission found prejudicial;
  • a report made unanimously or by an unidentifiable person;
  • if the infringement of public interest or important private interest is not proportional to the limitation of the rights of the person concerned in the report.

In connection with the management of their data, Whistle-blowers are entitled to request information about the management of their data, and are entitled to request the modification, deletion or freezing of their data and to lodge a complaint about the management of their data.Whistle-blowers are entitled to seek legal remedy against the refusal of requests or complaints made in connection with the management of their data before the court or to turn to the National Authority for Data Protection and Freedom of Information.

Further rules applicable to the management of the data of Whistle-blowers and the detailed rules for the data management activity of the Bank are set forth in the Data Protection Information Brochure of the Bank.

The Banks has reported the data management associated with the Whistle-blowing System to the data protection register kept by the National Authority for Data Protection and Freedom of Information.
Registration No.: NAIH-83783/2015.

Code of Ethics

If you wish to make a report on the violation of the Code of Ethics or another act that is, in your opinion, unlawful or is of moral concern, please contact the function of the Erste Bank Group in charge of investigations.

Postal address

Erste Bank Hungary Zrt. – Ethical Cases, H-1138 Budapest, Népfürdő u. 24-26., Hungary

email address

Reporting violations of the Code of Ethics on the Internet