The administrator of your personal data is Fado Sp. z o.o., based in Bydgoszcz, 7A Solna Street, 85-862 Bydgoszcz, e-mail: fado@fado.com.pl

• 1 [Introduction].

1. Pursuant to Article 24 of the Law of June 14, 2024 on the protection of whistleblowers (Journal of Laws of 2024, item 928), the following is established Internal notification procedure, which establishes rules for reporting Violations of Law, follow-up and protection of persons making reports of Violations of Law (whistleblowers).
2. Accepting reports of violations of the law is part of proper and safe management in the Companyand serves to increase the effectiveness of detecting irregularities and taking action to eliminate them and mitigate risks at all organizational levels.
3. The procedure for internal notifications was established after consultation with representatives of the Employer's workforce, selected in accordance with the employer's procedure. or company trade union organization(s) ........................(name).
4. Each person employed by the Companyis obliged to familiarize himself with the contents of the Internal Notification Procedure and to comply with it.

• 2 [Definitions].

Whenever the Internal Notification Procedure refers to:

• Follow-up - means the action taken to assess the truthfulness of the information contained in the notification and to prevent the Violation that is the subject of the notification, including investigation;
• Retaliatory Action - means a direct or indirect act or omission in a work-related context that is caused by a report or public disclosure and that violates or may violate the rights of the Signatory or causes or may cause unjustified harm to the Signatory, including the groundless initiation of proceedings against the Signatory.
• Feedback - it should be understood as the information provided to the Signatory on the planned or undertaken follow-up actions and the reasons for such actions;
• Information on a Legal Violation - means information, including reasonable suspicion, regarding an actual or potential Legal Violation that has occurred or is likely to occur at a legal entity where the whistleblower participated in the recruitment process or other pre-contract negotiations, works or worked, or at another legal entity with which the whistleblower maintains or has maintained contact in a work-related context, or information regarding an attempt to conceal such Legal Violation;
• Notification channel - it means technical and organizational solutions for making notifications;
• Violation of law or Infringement - an act or omission that is unlawful or intended to circumvent the law in the areas indicated in § 4. of the Procedures;
• Public authority - it should be understood as the chief and central government administration bodies, field government administration bodies, bodies of local self-government units, other state bodies and other entities performing public administration tasks by law, competent to take follow-up actions in the areas indicated in § 4. Procedures;
• Person affected by the notification - means a natural person, a legal person or an organizational unit without legal personality, to which the law confers legal capacity, identified in the notification or public disclosure as the person who committed the Infringement, or as a person with whom the person who committed the Infringement is associated;
• Internal Reporting Officer or Supervisor - means a person authorized by the Employer, ensuring impartiality, of good repute, with no criminal record, responsible for receiving reports and taking follow-up action, including investigation of the report,
• Employer or Company - it is understood to mean FADO Ltd. based in Bydgoszcz;
• Procedure - means the Internal Notification Procedure for receiving reports of violations of the law and taking follow-up action;
• Signatory - means an individual who makes a report (internal, external or public disclosure) of a Breach of Law in a work-related context, regardless of his/her position, form of employment or cooperation, entrepreneur, proxy, shareholder or partner, member of a body of a legal entity or unincorporated entity, a person performing work under the supervision and direction of a contractor, subcontractor or supplier, including under a civil law contract, intern, volunteer, trainee;
• Notification - means the oral or written communication of the Infringement to the Company;
• Internal notification - it should be understood as oral or written transmission of information about the Violation to the Employer;
• External notification - it shall be understood as oral or written communication to the Ombudsman or a public body of information about the Violation of Law.

• 3 [Making notifications].

1. The Internal Notification Officer, responsible for accepting notifications and exercising overall supervision over the acceptance of notifications and follow-up, is Ms. Agnieszka Jaskólska.
2. The proxy acts in an impartial, independent manner, based on the Company's authorization to receive applications and follow up.
3. A Proxy, as to whom it appears from the contents of the filing that he or she may be in any way involved in the act or omission that is the subject of the filing, may not analyze such filing. In such a case, the Whistleblower may make a report to any of the Company's Directors or Proxy, and that person shall in such case perform the functions of the Whistleblower Agent in the case.
4. The whistleblower can make a notification through the following channels:
   1. By mail to the mailing address: FADO Sp. z o.o. Agnieszka Jaskólska 7a Solna St. 85-862 Bydgoszcz with the note "CONFIDENTIAL - TO THE OWN HANDS OF THE APPLICANT".
   2. via e-mail to: agnieszka.jaskolska@fado.info, with the subject line of the message: "CONFIDENTIAL - IN THE HANDS OF THE NOTIFICATION ATTORNEY".
   3. By phone at: 52 370 79 79
   4. orally during a face-to-face meeting held within 14 days of receiving a request for such a form of notification.
5. With the consent of the Signatory, the oral submission will be documented in one of the following forms:
   1. A recording of the conversation, making it searchable,
   2. accurate transcription of the conversation<
   3. Minutes of the conversation, reproducing its exact course.
6. If the Signatory agrees to document an oral report, the Signatory may review, correct and approve the interview transcript or interview protocol by signing it.
7. The application should include a clear and complete explanation of the subject of the application, including at least:
   1. the date and place of the occurrence of the Infringement or the date and place of obtaining information about the Infringement;
   2. A description of the specific situation or circumstances creating the possibility of a Legal Violation;
   3. indication of the person to whom the notification applies;
   4. Indication of a possible victim;
   5. Identification of possible witnesses to the Violation;
   6. Identification of all evidence and information available to the whistleblower that may prove helpful in the process of processing the report;
   7. indicating the preferred method of feedback contact.
8. An application may only be made in good faith. It is prohibited to knowingly make a false report. According to the wording of the Law on the Protection of Whistleblowers of June 14, 2024 (Journal of Laws of 2024, item 928), a person who makes a report of false information is subject to a fine, restriction of freedom or imprisonment for up to 2 years.
9. A person who has made a report in which the truth has been knowingly misrepresented or concealed does not enjoy the protection provided for Whistleblowers.
10. The whistleblower can submit reports anonymously.

• 4 [Notifiable violations].

1. A violation of the law is an act or omission that is unlawful or intended to circumvent the law that applies:
   1. corruption;
   2. public procurement;
   3. services, products and financial markets;
   4. Prevention of money laundering and terrorist financing;
   5. Product safety and compliance;
   6. transportation security;
   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. privacy and data protection;
   14. Network and ICT system security;
   15. financial interests of the Treasury of the Republic of Poland, the local government unit and the European Union;
   16. the European Union's internal market, including public law competition and state aid rules and corporate taxation;
   17. constitutional freedoms and human and civil rights occurring in the relations of the individual with public authorities and not related to the areas indicated above.
2. A report may relate to a reasonable suspicion of an actual or potential Violation that has occurred or is likely to occur at the Employer.

• 5 [Analysis of notification, investigation].

1. Access to the reporting channels is provided by the Reporting Supervisor, who is responsible for receiving reports and following up on them.
2. Upon receipt of a filing, the Plenipotentiary shall take steps to assess the veracity of the information contained in the filing, including verification of the filing and further communication with the Signatory. If warranted by the content of the notification, the Plenipotentiary may request additional information from the Signatory regarding the notification and provide feedback on the notification.
3. The Signatory shall receive an acknowledgement of receipt of the notification within 7 days of receipt of the notification, unless the Signatory has not indicated a contact address to which such acknowledgement should be forwarded. In the case of a verbal notification, the Signatory shall receive confirmation of acceptance of the notification at the meeting at which the notification is made.
4. The Notification Commissioner may decide not to conduct an investigation when the content of the notification shows that it is indisputably false or it is impossible to obtain the information necessary for the investigation.
5. A notification that allows for an investigation is subject to immediate processing.
6. The Notification Officer may engage, if deemed appropriate, representatives of the Employer's organizational units or independent consultants to participate in the investigation.
7. The notification officer shall recognize the notification, follow up, provide feedback without undue delay, no later than 3 months after the confirmation of acceptance of the notification, or in case of failure to provide confirmation of acceptance of the notification - within 3 months after the expiration of 7 days of the notification.
8. After the investigation, the Notification Commissioner evaluates the legitimacy of the notification. In the case of a legitimate report, the Notification Commissioner shall make recommendations for appropriate corrective or disciplinary action against the person who committed the Violation and recommendations aimed at eliminating and preventing identical or similar Violations in the future.
9. In the event of negative verification of the notification, the Notification Officer shall immediately provide the Signer and the person to whom the notification applies with information about the notification made and the results of the verification carried out.

• 6 [Prohibition of retaliation].

1. It is prohibited to retaliate, attempt to retaliate or threaten to retaliate or threaten to retaliate against a whistleblower who has made a report, as well as public disclosure - in accordance with the Law on Protection of Whistleblowers of June 14, 2024 (Journal of Laws of 2024, item 928).
2. It is forbidden to retaliate against a person who helped the Signaller make a report and against a person who is affiliated with the Signaller.
3. Taking any repressive, discriminatory or otherwise unfair treatment against the Signatory will be treated as a Procedural Violation and may result in legal liability.
4. In particular, it is unacceptable with respect to the Signaller:
   1. refusal to establish an employment relationship;
   2. Termination or termination without notice of the employment relationship;
   3. failure to conclude a fixed-term employment contract or an indefinite-term employment contract after termination of the probationary contract;
   4. Failure to conclude another fixed-term employment contract or failure to conclude an indefinite-term employment contract after the termination of a fixed-term contract - when the employee had a legitimate expectation that such a contract would be concluded with him;
   5. reduction in labor compensation;
   6. Withholding promotion or being overlooked for promotion;
   7. omission in the award of work-related benefits other than wages or reduction in the value of such benefits;
   8. Transfer of the employee to a lower job position;
   9. Suspension from the performance of labor or official duties;
   10. The transfer to another employee of the employee's existing duties;
   11. An unfavorable change in the place of work or work schedule;
   12. Negative performance evaluation or negative opinion of the work;
   13. the imposition or application of a disciplinary measure, including a financial penalty, or a measure of a similar nature;
   14. Coercion, intimidation or exclusion;
   15. bullying;
   16. discrimination;
   17. adverse or unfair treatment;
   18. Withholding participation or omission from typing for professional qualification training;
   19. unjustified referral for a medical examination, including psychiatric examinations, if separate regulations provide for the possibility of referring an employee for such examinations;
   20. An action to make it more difficult to find future employment in a particular sector or industry on the basis of an informal or formal sector or industry agreement;
   21. causing financial loss, including economic loss or loss of income;
   22. infliction of other immaterial damage, including Infringement of personal property, in particular, the good name of the applicant.
5. Retaliation for making a report or public disclosure is also considered to be a threat or attempt to take the measure specified in paragraph 3 above. The Employer shall bear the burden of proof that the action taken is not retaliatory.
6. A whistleblower filing a report in bad faith (i.e., filing a report knowing that the Infringement did not occur) is not subject to the protection provided for in the Procedure and in the Law on Protection of Whistleblowers of June 14, 2024 (Journal of Laws of 2024, item 928).
7. A person who has suffered damage due to a so-called "bad faith" filing has the right to demand compensation or damages for Infringement of Personal Property from the Signaller who made such filing.

• 7 [Data protection].

1. The personal data of the Signaller allowing to establish his/her identity shall not be disclosed to unauthorized persons, unless the Signaller consents to its disclosure.
2. The purpose of maintaining confidentiality is to guarantee the sense of security of the Whistleblower and to minimize the risk of retaliation or reprisals. A Whistleblower who has made a report and whose personal information has been unauthorizedly disclosed should immediately notify the Reporting Officer of the situation. The Plenipotentiary is obliged to take measures to protect the Whistleblower.
3. The identity of the Whistleblower, as well as all identifying information about the Whistleblower, will not be disclosed to the subjects of the notification, to third parties, or to other employees and associates of the subject. The identity of the Whistleblower, as well as other information enabling his or her identification, may be disclosed only if such disclosure is a necessary and proportionate obligation under generally applicable laws in the context of investigations or pre-trial or judicial proceedings conducted by public authorities or courts, respectively. The identities of the subjects of the notification are subject to confidentiality requirements to the same extent as the identity of the Whistleblower.
4. Personal information that is not relevant to the investigation of the application is not collected, and if accidentally collected, it is deleted within 14 days of the determination that it is not relevant to the case.

• 8 [Register of notifications].

1. Each notification is subject to registration in the Notification Register, regardless of the course of follow-up.
2. The Notification Supervisor is responsible for maintaining the Notification Register.
3. The Register of Applications shall contain, at a minimum:
   1. application number;
   2. Subject Violations;
   3. personal data of the Whistleblower and the subject of the notification, necessary to identify them;
   4. Signalman's contact address;
   5. the date of internal notification;
   6. Information on follow-up actions taken;
   7. date of completion of the case.
4. The Register of Notifications is maintained under the rules of confidentiality. Personal data and documents related to the notification are kept for a period of 3 years after the end of the calendar year in which the follow-up action was completed, or after the completion of the proceedings initiated by these actions, or after the notification is forwarded to the public authority competent to take follow-up action.

• 9 [Information on external notifications].

1. Notification may also be made to the Ombudsman or a public body in any case, bypassing the Procedure, in particular when:
   1. within the deadline for feedback with the Employer, no follow-up or feedback was provided
   2. The whistleblower has reasonable grounds to believe that the Violation may pose a direct or obvious threat to the public interest, there is a risk of irreparable harm, or making an internal notification will expose the whistleblower to retaliation,
   3. if an internal notification is made, there is little likelihood of the Employer successfully preventing the Infringement due to the special circumstances of the case, such as the possibility of concealment or destruction of evidence or the possibility of collusion between the Employer and the perpetrator of the Infringement or the Employer's participation in the Infringement.
2. A notification made to the Ombudsman or a public body bypassing internal notification does not result in depriving the whistleblower of the protection guaranteed by the provisions of the Law of June 14, 2024 on the Protection of Whistleblowers (Journal of Laws 2024.928).
3. The Employer's goal is to increase the effectiveness of detecting irregularities and taking effective measures to address them and effectively manage risks, and to increase trust among employees and business partners. The Employer encourages the use of the Procedure when there is an opportunity to remedy a Legal Violation within the Employer's structure.

• 10 [Final provisions].

1. The procedure enters into force 7 days after it is made known to those employed by the Employer.
2. The Procedure will be published on the Employer's website at: www. fado.info, www.coolingcare.eu, and will be made known to employees by forwarding the contents of the Procedure in e-mail form to employees' individual addresses (with the obligation to confirm receipt of the message) or in writing against receipt.

 Bydgoszcz on 01.10.2024r.

Management of the Company