ASA CONS ROMANIA SRL, headquartered in Turda, 22 Decembrie 1989 Street, no. 27, Cluj County, registered at the Trade Register Office under no. J12/2666/2002, CUI 10817290, tax attribute RO, account IBAN RO52 BTRL RONC RT02 0755 7201, opened at Banca Transilvania Turda Branch, e-mail: contact@asacons.ro, phone: 0264.31.30.24, fax: 0264.31.70.57, legally represented by administrator Bulgaria Bogdan-Octavian, hereinafter referred to as “the Company”

In view of the

• The desire to carry out the activity in compliance with the national and European legislative framework, having a zero-tolerance policy towards any violation of the referred provisions;

• The entry into force of Law no. 361/2022 on whistleblowers;

•  The need to provide both employees and business partners with a working environment with a high degree of trust, to encourage the Company’s employees, but also the partners with whom the Company collaborates to report information regarding any actual or potential violations of the law, which have occurred or are likely to occur within the Company, as well as information on attempts to conceal such violations;

adoptă prezentul set de reguli în materia raportării informațiilor referitoare la încălcările legii:

Art.1. Scope

(1) This procedure applies to reporting individuals (hereinafter referred to as the “Reporting Person” or the “Whistleblower”) and who have obtained the information regarding violations of the law, as defined in Art. 3 item 1 and Annex no. 2 of Law no. 361/2022, in a professional context.

(2) The category of natural persons who can have the quality of whistleblowers, includes, but is not limited to, employees (current / in the process of being recruited / whose employment relationship has ended), volunteers, trainees, associates, any collaborators or employees of the Company’s collaborators/suppliers/subcontractors.

(3) Information relating to breaches of law refers to information, including reasonable suspicion, about actual or potential breaches of law, which have occurred or are likely to occur within the Company, in which the whistleblower works or has worked in the public interest or with which he is or has been in contact through his activity, as well as information on attempts to conceal such violations.

Art.2. Internal reporting of a violation of the law

(1) Reporting of violations of the law is carried out through the following internal reporting channels, managed by the NAVEX third party[1]:

[1] NAVEX, established in Stockholm, World Trade Centre, WhistleB City Office, Klarabergsviadukten 70111 64, Sweden, telephone 46 725 47 76 00:

a. In writing, in electronic format, by accessing the https://consolis.ethicspoint.com or https://consolismobile.ethicspoint.com pages (hereinafter referred to as the “Website”); 
b. By calling the telephone line 0800 890 421.

(2) At the request of the whistleblower, the reporting can also be carried out through a face-to-face meeting, with the person designated on behalf of the company to take over the report, who will draw up a recording report, with the consent of the person making the report. The designated person gives the whistleblower in the public interest the opportunity to verify, rectify and agree to the minutes of the conversation by signing it. The designated person assumes all confidentiality obligations set out in this procedure.

(3) The reporting will include the following information:

a. name and surname, contact details of the whistleblower in the public interest;
b. the professional context in which the information was obtained;
c. the data subject, if known;
d. the description of the fact likely to constitute a violation of the law within the Company;
e. evidence in support of reporting;
f. date;
g. the whistleblower’s signature.

(4) By exception to the provisions of para. (3), anonymous reporting is also allowed. A 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 indications of violations of the law.

(5) In the case of telephone reports, the same information that would be included in writing will be requested, and the whistleblower’s answers will be entered on the Website by a NAVEX interviewer.

(6) NAVEX will ensure the record of the reports, in electronic format, in a register that will include the date of receipt of the report, the name and surname, the contact details of the whistleblower in the public interest, the object of the report and the method of resolution.

Art.3. Ensuring the confidentiality of internal reporting

(1) After submitting the complaint through the internal channels provided for in Art. 2, the whistleblower will be assigned a unique code, called the “complaint code”, which automatically confirms the receipt of the report. The whistleblower must keep this code and password in a safe place, being solely responsible for this. After 7 working days, the whistleblower can use the report code and password to check the status of his complaint, within the Follow-up section of a complaint on the Website.

(2) The reports are stored on EthicsPoint’s secure servers, belonging to the third party NAVEX, and are not managed by the Company. The alert channel does not generate or archive internal connection reports with IP addresses. There will be no information connecting the whistleblower’s PC to the alert channel. The third-party service provider, NAVEX, contractually undertakes not to seek to identify the person making a complaint.

(3) The confidentiality of the identity of the reporting person is and will always be ensured. The identity/information that could lead to the inference of the identity of the person making the report will not be disclosed to any other person, without the express consent of the whistleblower, except for the members of the Alert Committee set up at the level of Consolis, the third party that will resolve the report.

(4) By way of derogation from para. (3), disclosure may take place only where required by law, in the context of investigations carried out by national authorities or judicial proceedings. In such a case, the reporting person will be informed before his or her identity is disclosed, unless such information would jeopardise related investigations or legal proceedings.

Art.4. Procedure for solving internal reporting

(1) The report submitted through the internal channels will be communicated to the Alert Committee established at the level of Consolis OY, a Finnish company, having its registered office at Hiidenmaentie 20 03100 Nummela, Finland, founding act no. 1108263-8 issued by RNMI Finland, the third party designated to settle reports (hereinafter referred to as the “Consolis OY Alert Committee”)). The reporting person receives an acknowledgement of receipt of the report within 7 days of receipt of the report by the Consolis Alert Committee.

(2) The Consolis OY Alert Committee will verify the validity of the report and conduct a prompt and thorough investigation, respecting the principles of impartiality, fairness and confidentiality towards all parties involved.

(3) During the investigation, assistance may be requested from specific departments (such as finance, human resources, legal, etc.). If necessary, the assistance of specialized external consultants can also be requested.

(4) During the investigation, it may be necessary for the whistleblower to be contacted to discuss the facts presented and/or to obtain additional information that is considered essential for the verification of reporting, but he is not obliged to provide such information. All communications with the reporting person will be made confidentially and anonymously (if this has been his/her choice).

(5) All personal data and information of the whistleblower and any other parties involved, which are obtained through the internal whistleblowing channel (including any sensitive data such as racial and ethnic origin, religious and philosophical beliefs, political opinions, membership of political parties or trade unions, and personal data indicating an individual’s health and sexual orientation) will be processed in full compliance and in accordance with the provisions of the relevant legislation in force at the time of handling such personal data and information and, in any case, in accordance with the legal provisions on the protection of personal data. The reports will be stored for 5 years, according to art. 7 para. (2) of Law no. 361/2022.

(6) The Consolis Alert Committee undertakes to inform the reporting person, to the extent legally possible and in the most comprehensive way possible, of the progress of the investigation and its outcome.

(7) The reporting person will be informed by the Consolis Alert Committee, insofar as there are no legal impediments in this regard, within a reasonable period of time, of the actions envisaged or taken as a result of the reporting and of the reasons for choosing these subsequent actions, which will not exceed 3 months from the acknowledgement of receipt or, if no confirmation has been sent to the reporting person, 3 months after the expiry of the seven-day reporting period.

(8) Consolis’ Alert Committee, acting as an indirect associate of the Company, may take any action it deems necessary to remedy the reported breach.

(9) The Consolis Alert Committee will also inform the Company about how to resolve the report and notify the public authorities/institutions, if necessary.

Art.5. Classification of internal reporting

(1)  Reporting is ranked when:

a. does not contain the elements provided for in art. 2 para. (3), other than the identification data of the whistleblower in the public interest, and the Alert Committee of Consolis requested its completion within 15 days, without this obligation being fulfilled;

b. the report is submitted anonymously and does not contain sufficient information regarding violations of the law, which would allow the analysis and resolution of the report, and the designated person has requested its completion within 15 days, without this obligation being fulfilled;

c. Upon examination of the report, it is found to be a clearly minor breach and does not require further follow-up action other than the closure of the procedure, without prejudice to the obligation to maintain confidentiality, to inform the whistleblower in the public interest, and is without prejudice to any other obligations or applicable procedures to remedy the reported breach.

(2) If a person makes several reports with the same object, they are connected, the whistleblower in the public interest receiving only one information. If, after sending it, a new report is received with the same subject, without presenting additional information justifying a different subsequent action, it is closed.

(3) The closure solution shall be communicated to the whistleblower, indicating the legal basis, except for the hypothesis reviewed in para. (1) letter b).

Art.6. External reporting of a violation of the law

(1) The whistleblower may choose to make an external report of the violation of the law, in which sense he may address the National Integrity Agency (hereinafter referred to as “ANI“), in the following ways:

a. Online, on the Whistleblowers Platform https://avertizori.integritate.eu;
b. By e-mail to avertizari@integritate.eu;
c. By phone, at 0372.069.869 by selecting the keys 1 (Select Romanian), 0 (Consent to record conversation), 3 (Whistleblowers in the Public Interest Department). Conversations will be automatically recorded;
d. Through postal services at the address of ANI at 15 Lascăr Catargiu Boulevard, Postal Code 010661, Sector 1, Bucharest, Romania, with the mention To the attention of the Whistleblowers in the Public Interest Department;
e. In person, by being present at the ANI headquarters in 15 Lascăr Catargiu Boulevard, Sector 1, Bucharest, Romania with prior appointment made at the email address avertizari@integritate.eu).

(2) Avertizorul poate alege în mod liber calea de raportare dorită, internă sau externă.

Art.7.Prohibition of retaliation

(1) Any form of retaliation against whistleblowers in the public interest, threats of retaliation or attempted retaliation is prohibited, in particular those concerning:

a. any suspension of the individual employment contract or of the service relationship;
b. dismissal or dismissal from public office;
c. modification of the employment contract or the employment relationship;
d. salary reduction and change of working hours;
e. demotion or hindrance of promotion to work or public service and professional development, including through negative evaluations of individual professional performance, including of civil servants, or through negative recommendations for the professional activity carried out;
f. the application of any other disciplinary sanction;
g. coercion, intimidation, harassment;
h. discrimination, creating another disadvantage or subjecting them to unfair treatment;
i. refusal to convert a fixed-term employment contract into an employment contract of indefinite duration, where the worker had legitimate expectations that he would be offered a permanent post;
j. refusal to renew a fixed-term employment contract or early termination of such a contract;
k. causing damage, including to the reputation of the person concerned, in particular on social media, or financial loss, including in the form of loss of business opportunities and loss of income;
l. inclusion on a negative list or database, based on a sectoral or industry-wide agreement, formal or informal, which may mean that the person concerned will not find a job in the sector or industry in the future;
m. unilateral out-of-court termination of a contract for goods or services, without the conditions being met;
n. cancellation of a licence or permit;
o. request for a psychiatric or medical assessment.

(2) In the event that the whistleblower will be subject to disciplinary investigation within a maximum of one year from the date of reporting, he/she has the right to request the Bar Association in the district of the place of activity to provide free legal aid during the disciplinary procedure.

(3) Any measure taken by the Company against the whistleblower, provided for in para. (1) may be challenged in court by the latter, the whistleblower having the right to request free legal aid from the Bar Association in the district of the place of activity.

Art.8. Final provisions

(1)  The present procedure is supplemented by the provisions of Law no. 361/2022 on the protection of whistleblowers in the public interest, with subsequent amendments and completions.

(2) Any amendment to Law no. 361/2022 will prevail over the present procedure.

(3) This procedure was revised on 01.06.2025.

ASA CONS ROMANIA SRL
Through the administrator,
Bulgaria Bogdan-Octavian