The Company announces that the Company has established the Procedure for Reporting Breaches and Taking Follow-up Actions at Medicalgorithmics S.A., headquartered in Warsaw, Poland (hereinafter the “Procedure”). The Company has adopted the Procedure, which replaced the Company’s previous Procedure for reporting violations at Medicalgorithmics S.A. /Whistleblowing Policy/, in connection with the entry into force of the Law on Protection of Whistleblowers dated June 24, 2024.
The procedure takes into account:
- the provisions of the Act of July 29, 2005. on Public Offering and Conditions for Introducing Financial Instruments to the Organized Trading System and on Public Companies (the “Offering Act”) with respect to the Company’s obligation as an issuer within the meaning of the Offering Act to have, implement, maintain and update a procedure for anonymous reporting by employees to a designated member of the management board, and, in specific cases, to the supervisory board, violations of the law, in particular the provisions of the Offering Act and the Regulation (EU) 2017/1129 of the European Parliament and of the Council on the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market and repealing Directive 2003/71/EC of June 14, 2017. and ethical procedures and standards,
- the provisions of the Act of June 24, 2024 on the protection of whistleblowers (the “Whistleblower Protection Act”) implementing into the Polish legal order the Directive of the European Parliament and of the Council (EU) 2019/1937 of October 23, 2019 on the protection of whistleblowers. The procedure constitutes the internal procedure established by the Company as a legal entity within the meaning of the Law on the Protection of Whistleblowers, for making reports of violations of law and taking follow-up actions, in accordance with the requirements set forth in the said law.
According to Article 3(1) of the Law on the Protection of Whistleblowers,
a violation of the law is an act or omission that is unlawful or intended to circumvent the law, relating to, among other things:and corruption; public procurement; financial services, products and markets; anti-money laundering and terrorist financing; product safety and compliance; public health; protection of privacy and personal data; security of information and communication networks and systems; financial interests of the State Treasury of the Republic of Poland, a local government unit and the European Union.
The Company shall ensure that the processing of personal data related to the receipt of reports prevents unauthorized persons from gaining access to the information covered by the report and shall ensure that the confidentiality of the identity of the whistleblower, the person to whom the report relates and the third party named in the report is protected.
The Company shall ensure that the processing of personal data related to the receipt of reports prevents unauthorized persons from gaining access to the information covered by the report and shall ensure that the confidentiality of the identity of the whistleblower, the person to whom the report relates and the third party named in the report is protected.
A report of a violation may be made in Polish or English either
anonymously or
with personal information that allows the whistleblower to be identified and contacted, including the whistleblower’s name and contact address or telephone number, in one of the following ways:
- electronically to the e-mail address: whistleblower@medicalgorithmics.com, and in the case of submissions concerning: the Board of Directors as a body acting collectively or individual Board Members, individual Supervisory Board Members – to the Supervisory Board at e-mail address:
whistleblowerRN@medicalgorithmics.com;
- in writing in a closed double envelope – with the necessary notation on the inner envelope “NOTIFICATION OF SIGNALIST”, placed in the outer envelope addressed to the Company’s address: Medicalgorithmics S.A., Al. Jerozolimskie 81, 02-001 Warsaw – delivered to the Company’s address,
- in oral form through an application made in person during a meeting organized at the request of the applicant.
i 1. A violation of the law is an act or omission that is unlawful or intended to circumvent the law, concerning:
1) corruption;
2) public procurement;
3) financial services, products and markets;
4) prevention of money laundering and financing of terrorism;
5) product safety and compliance;
6) transportation safety;
7) environmental protection;
8) radiological protection and nuclear safety;
9) food and feed safety;
10) animal health and welfare;
11) public health;
12) consumer protection;
13) protection of privacy and personal data;
14) security of networks and information and communication systems;
15) inancial interests of the State Treasury of the Republic of Poland, local government unit and the European Union;
16) the internal market of the European Union, including public law principles of competition and state aid and corporate taxation;
17) constitutional freedoms and rights of man and citizen – occurring in the relations of the individual with public authorities and unrelated to the areas indicated in items 1-16.
