1. Introduction

The primary objective of Unicars Ltd is to maintain a high standard of business transparency as well as to ensure that all its actions comply with the standards of business ethics and professional conduct as outlined in the Code of Conduct and Professional Behaviour posted on www.unicars.com. At the same time, our main concern is to safeguard the reputation and safety of all parties affected by our organisation’s activities. 

2. Purpose

In this context, our organisation has a whistleblowing mechanism which enables the reporting of suspected mismanagement, behaviours that are inconsistent with our Company's values as well as possible offences, if someone reasonably considers that their reporting is in the public interest. 

• The Company has appointed the Human Resources Department as the Receiving Officer (R.O.) for reports/complaints. The R.O. acknowledges receipt of the report/complaint to the reporting person within seven (7) working days from the date of receipt. In addition, the R.O. informs the reporting person of the actions taken and the findings of the investigation within a reasonable period of time, not exceeding three (3) months from the receipt of the report/complaint. 
• Unicars guarantees that all reports/complaints received will be handled confidentially, ensuring the anonymity of the reporting person unless disclosure is deemed necessary for the effective investigation of the case.
• All reports/complaints, irrespective of how they are submitted (see paragraph 4), are stored as received in a central electronic record. All relevant actions resulting from the investigation of the report/complaint and the persons in charge are entered in the electronic record. The R.O. is responsible for the storing and maintenance of the electronic record. The electronic record is stored for three (3) years unless there are grounds for longer storage (e.g. judicial proceedings).  
• In addition, the Board of Directors is informed on an annual basis of any reports/complaints. 

4. Channels for Managing Reports/Complaints Based on their Nature and Origin

• Submission of report/complaint by an employee or a third person concerning discrimination or harassment, such as verbal or physical, disrespect towards a person on grounds of their origin, religion, sexual orientation, special status or other: Investigation by the Human Resources Department with immediate briefing and ongoing updates to the CEO on the progress of the investigation. 
• Submission of report/complaint by an employee or a third person concerning a violation of the Code of Conduct and Professional Behaviour other than those described in section 4.1. above: Investigation by the Human Resources Department in cooperation with the COO and briefing of the CEO on the progress of the investigation.
• Submission of report/complaint concerning the R.O. or his/her Department:  Investigation by the CEO of the Company involving any person deemed necessary. In this case, the CEO keeps a separate electronic record until the investigation is completed, whereupon it is transferred to the central electronic record.

Any party affected by the activities of Unicars Ltd may file a report/complaint in one of the following ways:

1. By email to whistleblowing@unicars.com. 
2. By letter. 
3. Orally: In this case, the report/complaint will be electronically recorded in detail by the R.O. and entered by the latter in the central electronic record. 
4. Electronically via the tool in the respective link on the Company's website. In this case, the reporting person automatically receives a dedicated email address through which he/she can be kept up to date on the progress of the investigation of the report/complaint by the Company.

Reports/complaints can be submitted named or anonymously. The Company may contact the reporting person for the purpose of conducting the investigation. The Company treats all submitted reports/complaints with utmost confidentiality.

6. Documentation of an Oral Report/Complaint

If the report/complaint was made orally, by telephone or other telephone messaging system or during a face-to-face meeting, internal reporting channels may document the oral submission:

(a) by recording the conversation in a secure and retrievable format (e.g. a recording), upon obtaining the prior consent of the reporting person,

(b) by keeping complete and accurate minutes of the complaint.

In all cases, reporting persons must be provided with the opportunity to verify and correct the content of the recorded conversation. If the reporting person agrees with the content of the recorded conversation, they sign it.

Personal data collected in the context of receiving and monitoring reports/complaints are deleted within three (3) months from the date of completion of the monitoring procedure.

In the event that judicial or disciplinary proceedings have been initiated against the reported or the reporting person (including appeal or objection proceedings), the personal data are retained throughout the duration of these proceedings, and up to one (1) year following their conclusion. If and when the three (3) years referred to in paragraph 3 above have elapsed, the personal data are deleted. 

Any form of retaliation against persons who have submitted a report/complaint, including threats and acts of revenge, are prohibited. 

In particular, the following forms of retaliation are prohibited:

(a) termination, dismissal or other equivalent measures;

(b) demotion, failure to promote or deprivation of promotion;

c) removal of duties, change of place of work, reduction of salary, change of working hours;

(d) deprivation of training;

(e) negative performance appraisal or negative professional recommendation;

(f) reprimand, disciplinary or other measure, including a fine;

(g) coercion, intimidation, harassment or marginalisation;

(h) discrimination or unfair treatment;

i) non-conversion of a temporary employment contract into a permanent contract;

(j) non-renewal or early termination of a temporary employment contract;

(k) intentional harm, including damage to reputation, in particular on social media, or financial loss, including business loss and loss of income.

8. Confidentiality of the Identity of the Reporting & the Reported Persons

The internal report/complaint submission channels ensure the confidentiality of the identity of the reporting and the reported persons or any other information from which the identity of these persons can be directly or indirectly deduced. The Company undertakes not to disclose the above information to any persons other than those authorised to receive or monitor the complaints.

In exceptional cases, the identity of the reporting person may be disclosed if:

(a) he/she expressly consents thereto;

(b) disclosure is a necessary and proportionate obligation imposed by Union or National law in the course of investigations by national authorities or judicial proceedings, e.g. for the purpose of safeguarding the right of defence of the person against whom the report/complaint is made.

Before disclosing the identity of the reporting person, and provided that this does not undermine the investigations or judicial proceedings, the internal reporting channels are required to inform the reporting person accordingly and send him/her a written justification explaining the reasons for the disclosure.

9. Malicious Reports/Complaints

Reports/complaints that abuse the relevant legislative framework for the purpose of causing harm or damage fall under the provisions of Law 6(I)/2022 and will be dealt with accordingly.