Preamble
Buglo Play sp. z o.o. conducts its operations in accordance with generally applicable laws, the highest ethical standards and best business practices, adhering to the values and principles that guide all its activities. To ensure this compliance and to protect principles and prevent unacceptable practices, Buglo Play sp. z o.o. implements a system for reporting and handling incidents that constitute violations of applicable laws, ethical principles and internal procedures called the Buglo Play sp. z o.o. Whistleblower Procedure.
The purpose of the Procedure is to prevent, detect and clarify irregularities in the fields indicated above.
§ 1
Definitions and Abbreviations used in the Procedure
Buglo Play sp. z o.o. – the company Buglo Play sp. z o.o., based in Koszalin, KRS 886974.
Organizational unit - a business unit, a plant that is part of Buglo Play Sp. z o.o
Organizational cell - an office, department, independent position and other organizational structures occurring in Buglo Play sp. z o.o., directly or indirectly subordinate to the managers of the Organizational Units.
Irregularity – any potential violation of generally applicable laws, rules, generally applicable customs, internal rules or procedures applicable to Buglo Play sp. z o.o., including the Code of Business Conduct, the Anti-Corruption Policy, Buglo Play sp. z o.o.'s Internal Procedure for Prevention of Money Laundering and Financing of Terrorism, anti-trust law, and cartel pricing in particular. Irregularities are, in particular, theft, giving or accepting a bribe, taking discriminatory actions, harassment, mobbing
Procedure – the Whistleblower Procedure at Buglo Play Sp. z o.o.
Employee – any person employed by Buglo Play sp. z o.o. on the basis of an employment contract or civil law contract.
President – President of the Management Board of Buglo Play Sp. z o.o.
Supervisor – the person who supervises an Employee or, in the case of civil law contracts, receives the results of their work.
Chairman – the person who chairs the Surveillance Team appointed to clarify reported Irregularities.
Whistleblower – any person submitting a Report.
Management Board – Members of the Management Board of Buglo Play sp. z o.o
Team / Surveillance Team - a team of individuals responsible for explaining or evaluating the Report, as well as recommending corrective actions to eliminate or minimize the risk of Irregularities.
Report – a signal coming from an Employee or another person about a suspected Irregularity, reported through one of the dedicated channels described in the Procedure.
§ 2
Addressees of the Procedure
The procedure is addressed to all Employees of Buglo Play sp. z o.o., and the principles and rules contained therein are applicable at all levels of the organizational structure of each Organizational Unit.
§ 3
Procedure Implementation Team
1. In order to implement the provisions of the Procedure, the Management Board appoints a Surveillance Team.
2. In the event that a Report concerns a member of the Surveillance Team, in order to clarify the Report and properly conduct an internal investigation of the matter, that member of the Team shall be excluded from the activities of the Team, and another Board Member shall take his place. By decision of the Chairman, another person may also be included in its composition in such a situation.
3. The team makes decisions by majority vote. In the event of an equality of votes, the Chairman's vote shall prevail.
§ 4
Rules and regulations for Whistleblowing
1. An employee who observes an Irregularity or has a suspicion of its occurrence should immediately report it through one of the dedicated channels:
a) confidential Personal Report to a Superior, HR department or a member of the Company's Management Board, who shall immediately forward the information obtained to This email address is being protected from spambots. You need JavaScript enabled to view it.,
b) confidential or anonymous Report via email at: This email address is being protected from spambots. You need JavaScript enabled to view it.. The person responsible for systematically reviewing the above email box is the Team.
c) confidential or anonymous Report by means of a letter dropped into one of the boxes located at each Buglo Play Sp. z o.o. facility. The boxes will be emptied weekly, every Monday (or, if it is a holiday, on the next working day) by persons designated by the Team to do so. The designee shall forward the received letter immediately to This email address is being protected from spambots. You need JavaScript enabled to view it..
2. The report of suspected Irregularities should include all information (and, if possible, evidence) that will facilitate the establishment of the facts of the case and expedite the internal investigation. The Report should contain the following information in particular:
a) name of the person who, according to the whistleblower, committed the Irregularity,
b) Cell or Organizational Unit where the Irregularity took place,
c) date (period) of origin (duration) of the Irregularity,
d) description of the circumstances that, in the opinion of the Whistleblower, demonstrate the occurrence of the Irregularity,
e) indication of persons who have already been contacted by the Whistleblower on the issue,
f) indication of whether there is a threat to the health, life or safety of persons due to the Irregularity,
g) indication of the data of persons who may have any knowledge of the Irregularity or have witnessed it,
h) if possible – an indication of the legal basis for the violation, e.g., the provision of a specific internal document that the Whistleblower believes has been violated,
i) if possible – attach evidence, such as documents, photos, etc.
j) indication of other information that, in the opinion of the Whistleblower, may contribute to the establishment of the facts of the case and its clarification.
3. An employee is obliged to make Report in good faith, i.e. with the aim of the good of the functioning and operations of Buglo Play sp. z o.o., and not with the intention of personal gain, including hassling anyone.
4. No later than 7 working days from the date of receipt of the application, the Management Board shall set a date for a meeting of the Team, during which a decision will be made as to who is to conduct an investigation of the Report. Depending on the matter of the Report and the complexity of the case, the issue of clarifying the case may be entrusted to one or more persons. The decision is communicated to selected persons in the manner customary in the organizational unit. These persons are simultaneously provided with the contents of the Report and any additional information and documents that may contribute to the clarification of the case.
5. The conduct of the investigation may be entrusted to any person to whom the Team deems it reasonable to entrust such a role.
6. The content of the Report is covered by confidentiality, which is to be respected by all entities that have become aware of it (including those that have performed technical activities with respect to the Report, particularly those involving printing or copying).
§ 5
Protection of the Whistleblower
1. Buglo Play sp. z o.o. guarantees to the Whistleblower that no sanctions of a repressive nature will be levied against the Whistleblower and that the Whistleblower will be protected against any discrimination or other types of unfair treatment by Buglo Play sp. z o.o. or other Employees.
2. The Whistleblower has the right to inform the members of the Team of any violation of the guarantees indicated in § 5.1 above.
3. Violation of the above-mentioned guarantees will result in disciplinary consequences for the Employee who has committed it, in particular, it will constitute a grave violation of basic labor obligations, justifying termination of the employment contract due to the Employee's fault, and may also constitute an independent basis for termination of the civil law contract linking the Employee with Buglo Play sp. z o.o.
§ 6
Principles and rules for conducting an internal investigation
1. Those appointed to conduct the investigation are to conduct it thoroughly, promptly, confidentially, impartially, and in compliance with applicable laws.
2. If there is any doubt on the part of the entity conducting the internal investigation as to the manner of conducting it, such entity is obliged to seek the recommendation of the Chairman. The Chairman, after consultation with those whose support they deem useful and justified, is required to make a recommendation.
3. The entity conducting the internal investigation of a case has the following powers:
a) to enter any premises, including, for example, warehouses, server rooms and other facilities of the investigated Unit or Organizational Cell in the presence of persons materially responsible for the property located in these premises,
b) access to all files and documents (including the ability to make copies or printouts) that, in the opinion of the entity conducting the internal investigation, are necessary to establish the facts, to the extent permitted by generally applicable laws and internal regulations,
c) full access to information systems (including the Employee's business mailboxes) and data systems upon approval by the Board,
d) to obtain verbal or written explanations from Employees regarding the matter related to a particular Report,
e) to obtain oral or written explanations from external parties when the need arises,
f) to secure evidence of the Irregularity, including restricting access to the premises (facility, area, etc.) where the Irregularity occurred,
g) with the approval of the Management Board – ask for the assistance of professional external entities (law firms, consulting, auditing or other companies).
4. Each Report will be analyzed by the internal investigator for:
a) the financial impact on the operations of Buglo Play sp. z o.o.,
b) the anticipated disruption or stoppage of a particular process or its impact on Buglo Play sp. z o.o.'s business (e.g., by affecting the behavior and attitudes of other Employees),
c) impact of the Irregularity on the operation or business of Buglo Play sp. z o.o.,
d) risk of damage or loss of reputation of Buglo Play sp. z o.o.,
e) danger to the safety, health or life of Employees.
5. Upon completion of the investigation, the entity conducting the investigation shall forward all collected information and evidence to the Team, which may consider the Report as:
a) “Irrelevant.”
b) “Relevant– verified negatively” if the Team determines that the Irregularity did not occur or there is a lack of evidence/information necessary to confirm its occurrence,
c) “Relevant– verified positively”, if the Team finds that an Irregularity has occurred.
4. If the Report is considered significant – verified positively, the Team will take adequate action to remove the Irregularity and prevent its occurrence in the future. For this purpose, the Company may, in particular:
a) apply disciplinary sanctions to the Employee who committed the Irregularity,
b) file a notice of suspected crime with the police or refer the case to the police, special services or other state authorities,
c) take legal action against the wrongdoers to seek compensation for the damage suffered,
d) make recommendations on changing the way Buglo Play sp. z o.o. acts in a specific area.
5. All information, documents and evidence (whether in paper or electronic form) obtained in the course of an internal investigation will be treated as confidential. If necessary, they may be made available to the competent authorities in the course of administrative, criminal (including pre-trial or judicial) or civil proceedings or, with the approval of the Management Board, in the event of the need to use the assistance of professional third parties, including those entities such as law firms, consulting, auditing firms or others.
6. All reported Irregularities are subject to recording in the “Irregularities Record” maintained by the Chairman of the Team, to which the Team and the Board will have access. The data contained in the Irregularities Record is covered by confidentiality.
§ 7
Sanctions for non-compliance with the Procedure
Behavior inconsistent with the rules of the Procedure may violate the provisions of generally applicable law, which may result in the imposition of criminal, civil or administrative law sanctions on Buglo Play sp. z o.o. and on Employees of Buglo Play sp. z o.o. (e.g. fine, monetary penalty, exclusion from public contracts, loss of contracts), as well as result in damage to the reputation of Buglo Play sp. z o.o.
§ 8
Final provisions
1. The owner of this Procedure is Buglo Play sp. z o.o., based in Koszalin.
2. If any doubts arise regarding the interpretation of the provisions of the Procedure, an Employee is obliged to clarify these doubts with the Supervisor or the Team.
3. The procedure is reviewed and possibly updated at least once a year. The above actions are carried out by the Team, at the request of the Chairman.
4. Employees are required to sign a declaration that they are familiar with the Procedure and give it to the HR Manager at the time they start working with Buglo Play Sp. z o.o.