Visszaélés-bejelentési Szabályzat / Fraud Reporting Policy

Fraud Reporting Policy

I. General information

Taking into account Hungary's obligations
under international and EU law in line with
its anti-corruption efforts, and ensuring the
necessary measures to protect
Whistleblowers as fully as possible, the
Parliament, recognising the importance of
Whistleblowing in the private sector as
well, adopted the Act on Complaints and
Public Interest Disclosures, and on the
Rules of Whistleblowing Notifications (Act
No. XXV of 2023 (hereinafter referred to as
the "Complaints Act"), thereby obliging
CEE Thematics Ltd. (hereinafter referred to
as the "Company") to establish and
operate an internal fraud reporting system
(hereinafter referred to as the "Fraud
Reporting System").

II. Aim of the Policy

The purpose of establishing this Policy is to
enable all concerned party to report and
investigate actual abuse in a lawful manner and
to provide an opportunity for persons employed
by or contracted with the Company to raise
concerns about possible abuse and receive
feedback on the actions taken in this regard.
The stated purpose of the Policy is to ensure
that Whistleblowers are protected when
lawfully Reporting.
In the internal Fraud Reporting System reports
of information related to unlawful or allegedly
unlawful acts or omissions, including other
cases of fraud may be submitted.
This Policy sets out all the rules for
Whistleblowing, the functioning of the internal
Fraud Reporting System, the protection of the
Whistleblower and the procedure without any
discrimination.

III. Definitions

1) Complaint: A complaint is a request for
redress for a violation of an individual
right or interest, which is not subject to
any other procedure, in particular
judicial or administrative. A complaint
may also contain a proposal;
2) Public interest report: a public interest
report draws attention to a
circumstance the remedying or removal
of which is in the interest of the
community or society as a whole. A
public interest report may also include
a proposal;
3) Report or Whistleblowing: an oral or
written communication containing a
Complaint or a Public Interest Report,
which is submitted by the person
making the report to the recipient in the
Fraud Reporting System;
4) Reporting Person or Whistleblower:
the person w ho makes a report in t he
Fraud Reporting System;
5) Person Implicated in the Report: the
natural or legal person concerned by
the Report;
6) Foglalkoztatásra irányuló jogviszony :
any legal relationship where the
employee performs work for the
employer and under the employer’s
direction in exchange for consideration,
or works in the form of selfemployment;
7) Employer: an entity who employs a
natural person under contract for
employment relationship;
8) Employee: a natural person who
performs work for the employer and
under the employer’s direction under
contract for employment relationship in
exchange for consideration, or works in
the form of self-employment.

9) Good Faith: a Report is considered to
be made in good faith if the Report is
made with honest intentions and not
with the intention of causing harm to a
person or entity.
10) Policy: This Fraud Reporting Policy.

IV. The Fraud Reporting System

The Fraud Reporting System is operated by the
Legal and Compliance Department of the
Company, as provided for in Article 19 (1) of the
Complaints Act under the following contact:
E-mail: compliance_fraudreporting@antennaentertainment.
com

V. Who can make a Report?

In the internal Fraud Reporting System reports
of information related to unlawful or allegedly
unlawful acts or omissions, including other
cases of fraud may be submitted.
A Report may be submitted by:
a) by any Employee of the Company;
b) by an Employee whose employment
relationship with the Company has
been terminated; and
c) any person wishing to establish an
employment relationship with the
Company, provided that the procedure
for establishing this legal relationship is
pending.
d) by a private entrepreneur or sole
proprietorship if engaged under
contract with the Company;
e) by any person who holds an ownership
interest in the Company, as well as
persons belonging to the
administrative, management or

supervisory body of the Company,
including non-executive members;
f) by any persons working under the
supervision and direction of
contractors, subcontractors and
suppliers, provided that the procedure
for entering into a contract with the
Company is pending, or they were
engaged under contract with the
Company previously;
g) by the Company’s volunteers and
trainees;
h) by any person wishing to establish an
employment or contractual
relationship referred to in point d), e)
or g) with the Employer, provided that
the procedure for establishing such
employment or contractual
relationship is pending; and
i) by any person whose employment or
contractual relationship referred to in
point d), e) or d) with the Employer has
ended.

VI. Methods to make a Report

The Reporting Person may make the Report
orally or electronically, in writing by e-mail.
Oral Notification can be made in person, by
prior appointment at the Company's head
office (1133 Budapest, Váci út 76, 5th floor)
on working days.
If the Reporting Person makes his or her
Report in person, the operator of the internal
Whistleblowing system shall, after providing
information relating to the protection of
personal data, take the oral report into
account
a) make a recording of the oral Report
in a durable and retrievable form
b) make a transcript of the oral Report,
and shall offer the Reporting Person
the opportunity to check, rectify and
agree the transcript of the call by
signing it, and shall provide the
Whistleblower with a copy thereof.

The operator of the internal Fraud Reporting
System is required to make a complete and
accurate transcript of the oral Report.
In the case of an oral Report, the Reporting
Person shall be advised of the consequences
of making a Report in bad faith, to the
procedural rules governing the investigation
of the Report, and that his or her identity - if
he or she provides the necessary details for
establishing his or her identity - shall be
treated confidentially at all stages of the
investigation.
The operator of the internal Fraud Reporting
System shall send an acknowledgement of
the Report to the Reporting Person within 7
(seven) days of receiving the written report
made in the internal Fraud Reporting System.
The acknowledgement shall feature general
information for the Reporting person about
the procedural and data management rules
prescribed by the Complaints Act.
The Company cannot be held liable for any
failure to investigate cases where electronic
notifications do not reach the recipient's email
address as a result of the activity of
automatic protection software (antivirus,
spam filtering) or for other technical reasons.

VI.1 Investigation of the Report

The operator of the internal Fraud Reporting
System shall investigate the contents of the
Report within the shortest time possible under
the circumstances, not exceeding 30 (thirty)
days from the date of receipt of the Report. The
time limit specified herein may be extended on
a duly justified basis, of which the Reporting
Person shall be notified at the same time. In
that case, the Reporting Person shall be
informed of the estimated duration of the
investigation and the reasons for extending the
investigation. In either case, the time limit for
the investigation of the Report and for the
information of the Reporting Person may not
exceed 3 (three) months.
In the investigation of a Report, the operator of
the internal Fraud Reporting System shall
maintain communication with the Reporting
Person, and, in that context, it may request
further details and clarification of the Report

for ascertaining the relevant facts of the case,
and may request additional information as
well.
Investigation of the Report may be omitted if:
a) the Report was made by an
unidentifiable person;
b) the Report was made by a person not
authorized to do so under this Policy;
c) the Report made is identical to a
previous one submitted by the same
person; and/or
d) the harm to the public interest or a
compelling private interest would not
be proportionate to the Person
Implicated in the Report resulting from
the investigation of the Report.
The operator of the internal Fraud Reporting
System shall inform the Reporting Person in
writing about the investigation of the Report,
or the omission thereof showing also the
reason for the omission, the outcome of the
investigation of the Report, and the measures
taken or planned. Written information may be
omitted if the operator of the internal Fraud
Reporting System has verbally informed the
Reporting Person of the requirements and the
Reporting Person has acknowledged the
information. The operator of the internal
Whistleblowing system shall, on request,
provide clear information on the functioning of
the system set out in this Policy.

VII. Data processing provisions

1) Within the framework of the
internal Fraud Reporting System,
the personal data:
a) of the Reporting Person,
b) of the person whose
conduct or negligence gave
rise to the Report, and

c) of the person who may
have relevant information
about the contents of the
Report,
may be processed to the extent
absolutely necessary for the
investigation of the Report
solely for the purpose of
investigating the report and for
remedying or eliminating the
conduct that is the subject of
the Report.
2) Personal data not covered by
Subsection VII.1 shall be deleted
immediately from the data
processed within the framework of
the internal Fraud Reporting
System.
3) The personal data of the Reporting
Person – with the exception of the
data of the Reporting Person who
has obviously provided
information in bad faith or false
data - may only be disclosed to the
state body or authority competent
to conduct the proceedings
initiated on the basis of the
reporting, if this state body or
authority is entitled to process the
data by law or if the Reporting
Person has consented to the
disclosure of his/her data. The
personal data of the Reporting
Person shall not be disclosed
without his/her explicit consent.
4) If determined beyond doubt that
the complainant or the
Whistleblower has provided false
data or information in bad faith,
and
a) it gives rise to an indication
that a crime or an infraction
was committed, the personal
data of such person shall be
handed over to the body or

person entitled to carry out
proceedings,
b) where it is likely that the
complainant or the
Whistleblower caused
unlawful damage or other
harm to the rights of others, his
or her personal data shall be
handed over upon request to
the body or person entitled to
initiate or carry out
proceedings.
5) If the public interest disclosure
pertains to a natural person, the
personal data of the Whistleblower
may not be disclosed to the person
requesting the information in
exercising the right to information
and access according to the
provisions on the protection of
personal data accruing to this
natural person.
6) Data processed within the
framework of the internal Fraud
Reporting System may be
forwarded to a third country or
international organization only if
the recipient of the transmission
has made a legal commitment to
comply with the provisions of the
Complaints Act in connection with
Reporting and in due observation
of the regulations on the
protection of personal data.
7) The personal data of the Reporting
Person who reveals his identity, as
well as of the person implicated in
the Report for persons shall not be
disclosed to any person other than
the authorized person. Until the
conclusion of the investigation or
the opening of proceedings for
incurring formal liability as a result
of the investigation, the persons
investigating the Report shall be

allowed to share information about
the content of the Report and the
person implicated in the Report -
apart from informing the person
implicated in the Report - with
other organizational units or
Employees of the Employer to the
extent absolutely necessary for
conducting the investigation.
8) At the start of the investigation, the
person implicated in the Report
shall be informed in detail about
the Report, about his or her rights
in relation to the protection of his
or her personal data, and about the
rules for handling his or her data. In
accordance with the due process
principle, the person implicated in
the Report shall be given the
opportunity to express his or her
position regarding the Report also
through his or her legal
representative, and to provide
corroborating evidence. In
exceptional cases, the person
implicated in the Report may be
informed at a later time if
immediate information would
preclude the investigation of the
Report.

VIII. Protection of Whistleblowers

1) All measures adversely affecting
the Reporting Person:
a) which are taken on
account of making the
Report lawfully, and
b) which are implemented in
connection with the legal
relationship or relationship

defined in Section V. shall
be considered illegal even
if it would otherwise be
legal.
2) For the purposes of adverse
measures, the following, in
particular, shall be considered an
action or omission adversely
affecting the Reporting Person:
a) suspension, collective
redundancy, dismissal or
equivalent measures;
b) demotion or withholding
of promotion;
c) transfer of duties at the
place of work, change of
location of place of work,
reduction in wages, change
in working hours;
d) withholding of training;
e) a negative performance
assessment or
employment reference;
f) imposition or
administering of any legal
consequences considered
detrimental by law relating
to the employment
relationship, in particular,
disciplinary measure,
reprimand or other
penalty, including a
financial penalty;
g) coercion, intimidation,
harassment or ostracism;
h) discrimination,
disadvantageous or unfair
treatment;
i) failure to convert a
temporary employment
contract into a permanent
one, where the worker had
legitimate expectations
that he or she would be
offered permanent
employment;

j) failure to renew, or early
termination of, a
temporary employment
contract;
k) harm, including to the
person’s reputation or
financial loss, including loss
of business and loss of
income;
l) any measure where there
is reason to believe that it
may entail that the person
in question will not, in the
future, find employment in
the sector or industry
where he or she was
previously employed;
m) referral to examination
related to medical fitness;
n) early termination or
cancellation of a contract
for goods or services; and
o) cancellation of a license or
permit.
3) In administrative or judicial
proceedings related to the
detrimental measures referred to
in Subsection VIII.2., if the
Reporting Person is able to prove
the legality of Report:
a) it shall be presumed that
the detrimental measure
was taken on account of
making the Report
lawfully, and
b) the burden of proof to
corroborate that the
detrimental measure was
based on duly justified
grounds, rather than on
account of the Report
made lawfully, lies with
the person who has taken
the detrimental measure.
4) If the Report was made lawfully,
the Reporting Person shall not be
considered to have breached any

restriction related to the disclosure
of a statutory secret or any other
legal restriction relating to the
disclosure of information, and shall
not be held liable for such a Report
if the Reporting Person had
reasonable grounds to believe that
the Reporting of such information
was necessary for revealing the
circumstances affected by the
report.
5) If the Report is made lawfully, the
Reporting Person shall not incur
liability in respect of the acquisition
of or access to the information
which is Reported, provided that
such acquisition or access did not
constitute a self-standing criminal
offence. The Reporting Person
shall not be held liable for making
the Report lawfully, if the
Reporting Person had reasonable
grounds to believe that the
Reporting of such information was
necessary for revealing the
circumstances affected by the
Report. The Reporting Person may
refer to Subsections VIII.4-5. in all
administrative or judicial
proceedings, in addition to proving
the legality of the Report.
6) A Report shall be considered to
have been made lawfully if:
a) the Reporting Person
made his or her Report
through either of the Fraud
Reporting Systems defined
in this Policy, in accordance
with the provisions set out
in the Complaints Act,
b) the Reporting Person
obtained the information
Reported, related to the
circumstances affected by
the report in connection
with his or her workrelated
activities, and
c) the Reporting Person had
reasonable grounds to

believe that the
information Reported,
related to the
circumstances affected by
the Report was true at the
time of Reporting.
7) The protection given to Reporting
Persons shall be afforded to any
person who:
a) provides assistance to the
Reporting Person who
makes a lawful Report, in
making the Report;
b) maintains ties with the
Reporting person who
makes a lawful Report,
such as co-workers or
family members of the
Reporting Person, who
may b e s ubject t o t he
detrimental measure
provided for in Subsection
VIII.2.

IX. Final provisions

For matters not covered by this Policy, the
provisions of Act XXV of 2023 shall apply.

Valid from:
17 December, 2023