INFORMATION ON THE PROCEDURES OF INTERNAL REPORTING

This information is provided pursuant to Art. 12(4) of the Protection of Persons Who Report or Publicly Disclose Information on Breaches Act (PPRPDIBA).

  1. Who has the right to report?
    • current and former workers and employees
    • persons providing services under a civil contract
    • persons working as a freelancer or practicing craft activity
    • volunteers and paid or unpaid interns
    • contractors, subcontractors and suppliers
    • job applicants who have participated in a competition or some other form of selection for employment and in that capacity have been informed of a breach
    • persons reporting breaches that have been brought to their attention in a work context.
    NB! Anonymous reports shall NOT be processed.
  2. What kind of breaches should be reported?
  3. Breaches falling within the scope of the Bulgarian and European legislation in various areas, including:
    • public procurement
    • financial services, products and markets, and prevention of money laundering and terrorist financing
    • product safety and compliance
    • public health
    • transport safety
    • protection of the environment
    • radiation protection and nuclear safety
    • food and feed safety, animal health and welfare
    • consumer protection
    • protection of privacy and personal data
    • security of network and information systems.
    • breaches relating to the internal market in relation to acts which breach the rules of corporate tax or to arrangements the purpose of which is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law
    • breaches affecting the financial interests of the EU
    • breaches relating to the internal market, including breaches of EU competition and State aid rules
    • a committed criminal offence of a general nature, of which a reporting person has become aware in connection with the performance of their work or their official duties
    • employment legislation
    • legislation related to state services
    • rules for payment of outstanding public state and municipal receivables and others, referred to in PPRPDIBA.
    NB! Reports that are out of scope of PPRPDIBA shall not be processed.
  4. How can you file a report to "K Media Tech" Ltd.?
  5. You can file a report in writing by filling a template form. The template form may either be submitted to our staff member responsible for handling reports-Kameliya Zhiyanova or, alternatively, it can be sent to the following email address.
    reportandprotection [at] wpx.net



    NB! The report must be signed by the reporting person. If submitted electronically, the report shall be signed with a qualified electronic signature.

    NB! Using the template form is NOT mandatory, it is for the convenience of the reporting person as it outlines the required data that the report should contain. If the report does not comply with any one of the legal requirements, the staff member responsible for handling reports will send back a notice to the reporting person to rectify the irregularities within seven (7) days as of receipt of the report. If the irregularities are not rectified within this period, the report together with the documents thereto shall be returned to the reporting person.

    It is advisable to attach all written evidence to the report. The reporting person may also wish to identify other persons who could confirm the reported data or provide additional information.

    You can download the form HERE or contact the employee responsible for alert comments.

    An oral report may be submitted in one of the following ways:

    • by contacting the staff member responsible for handling reports at the following telephone number: +359 876493200;
    • at a scheduled in-person meeting with the staff member responsible for handling reports. Please arrange the meeting in advance using the provided telephone number.
    In these cases, our staff member responsible for handling reports will fill in the details in the template form and offer the reporting person the opportunity to check, rectify and agree with the transcript and the content thereof by signing it.
  6. What is the procedure after receiving the report?
  7. We will confirm the receipt of the report within seven (7) days and register it under a unique identification number (UIN). If the report does not meet the requirements of the PPRPDIBA, we will notify the reporting person to correct the irregularity within seven (7) days as of the receipt.

    The report shall be handled by a staff member, who is not in a position of conflict of interest.

    Within three months of receiving confirmation of the report, we will provide the reporting person with feedback on the results of the investigation and the actions undertaken in its course.

  8. What protection do the whistleblowers receive?
  9. The whistleblowers and their affiliates (e.g., colleagues or relatives) are protected against unlawful identity disclosure, except in the cases where such disclosure is permitted by the PPRPDIBA.

    Retaliation against protected persons is prohibited, namely: suspension, dismissal, demotion, a negative performance evaluation, application of financial and disciplinary liability, physical and verbal coercion, intimidation, hostility and violation of their dignity, discrimination, etc.

  10. What conditions should be met to receive protection?
  11. The whistleblower must have reasonable cause to believe that the information provided about the breach in the whistleblowing report was correct at the time of submission and that it falls within the scope of the PPRPDIBA; and the breach has been reported under the conditions and according to the procedure of PPRPDIBA.

    NB! Persons identified in a whistleblower’s report as offenders are entitled to compensation for all pecuniary and non-pecuniary damages when it is ascertained that the whistleblower knowingly submitted false information.

    • in writing form:
      - by the following email – whistleblowing@cpdp.bg
      - by post to the following address: 2 “Tsvetan Lazarov” Blvd., 1592 Sofia, Bulgaria
      - by the Secure Electronic Delivery System
    • in oral form – at CPDP’s address: 2 “Tsvetan Lazarov” Blvd., 1592 Sofia, Bulgaria

    The reporting person may use the Whistleblower Registration Form published on the CPDP website. The template form is optional. Should the reporting person choose to use it, he / she only need to fill in Part I to V (incl.) and sign it – when sending the form by post, with a handwritten signature; when sending it by e-mail, with a qualified electronic signature.

    When submitting a report via the Secure Electronic Delivery System, the CPDP staff member responsible for handling the report, will reach out to the reporting person for the purpose of completing the Whistleblower Registration Form under the PPRPDIBA.