The present notification for reporting violations ("Notification") aims to provide you with specific and accessible information regarding the terms and procedures for reporting violations through the internal channel of "Santera RE" Ltd, in accordance with the Law on Protection of Persons Reporting Violations or Publicly Disclosing Information about Violations ("Law").

WHAT VIOLATIONS CAN YOU REPORT?

According to Bulgarian legislation, you can report violations related to breaches of Bulgarian law or regarding acts defined in EU law in the following areas:

• public procurement;
• financial services, products, and markets, and the prevention of money laundering and terrorism financing;
• product safety and compliance, as well as transport;
• environmental protection;
• radiation protection and nuclear safety;
• food and feed safety, animal health, and animal welfare;
• public health and consumer protection;
• protection of personal data and privacy;
• network and information systems security;
• violations affecting the financial interests of the European Union as defined in Article 325 of the Treaty on the Functioning of the European Union and further specified in relevant Union measures;
• infringements of internal market rules within the meaning of Article 26(2) of the Treaty on the Functioning of the European Union;
• violations related to cross-border tax schemes;
• any offense of a general nature that you have become aware of in connection with the performance of your work or the discharge of your official duties.
• rules for the payment of due public state and municipal receivables;
• labor law.

WHO CAN REPORT VIOLATIONS?

Signals can be submitted and/or publicly disclosed by a natural person who becomes aware of violations in their capacity as:

• a worker within the meaning of Article 45(1) of the Treaty on the Functioning of the European Union, including employees, officials, civil servants, or any other person who performs work, regardless of the nature of the work, the method of payment, and the source of funding; a person who works without an employment relationship and/or exercises a liberal profession and/or a craft;
• a self-employed person within the meaning of Article 49 of the Treaty on the Functioning of the European Union, including a person who works without an employment relationship and/or exercises a liberal profession and/or a craft; a partner, shareholder, sole proprietor, member of the management or supervisory body of a commercial company, a member of the audit committee of an enterprise;
• a volunteer, paid or unpaid, and intern;
• a person who works for a natural or legal person, contractors, their subcontractors, or suppliers;
• a person whose employment or official relationship is about to commence in cases where information about violations is received during the selection process or other pre-contractual relations;
• a worker or employee when the information is obtained within the framework of an employment or official relationship that has terminated at the time of reporting the signal or public disclosure.

Protection is also provided to:

• individuals who assist the reporting person in the process of submitting a signal and whose assistance should be confidential; individuals who assist the reporting person in the process of submitting a signal;
• individuals connected through work or relatives to the reporting person who may be subject to retaliatory actions due to reporting;
• legal entities in which the reporting person holds a share, works for, or is otherwise associated with in a work context.
• In case the signal is reliable and well-founded, protection under the law is provided from the moment of submitting the signal or publicly disclosing information about the violation.

WHAT ARE THE CONDITIONS TO RECEIVE PROTECTION?

You have the right to protection provided that you:

• had reasonable grounds to believe that the information provided in the signal about the violation was accurate at the time of submission and that this information falls within the scope under point 2.
• reported a violation that may pose an immediate or explicit danger to the public interest or where there is an emergency situation or risk of irreversible harm;

No proceedings are initiated, and you do not receive protection regarding anonymous signals (unless subsequently identified) and signals relating to violations committed more than two years ago.

HOW AND WHERE CAN I SUBMIT A SIGNAL?

• In case you wish to report the violations specified in point 2 and if you have reasonable grounds to believe that the information is accurate, you may do so by sending an email to [email protected] . We will contact you within a 7-day period to complete the necessary form and/or address any irregularities. Oral reporting of a signal can be done by arranging a personal meeting with the following contacts: Vladimir Gagolevichin, Nikolay Marinov, and Radoslav Popov.
• When submitting an oral signal, we will record it on a form, which we will ask you to sign.
• The signal must contain at least: the full name, address, and phone number of the sender, email address (if available), names of the person against whom the signal is lodged (when filed against specific individuals known), specific details of the violation or the real danger of its occurrence, place and period of the violation, if it has occurred, description of the action or situation and other circumstances, as far as known to the reporting person, date, signature, electronic signature, or other identification of the sender.
• If there is a reasonable suspicion that there is a risk of retaliatory, discriminatory actions, and that effective measures will not be taken to verify the signal, the signal may be submitted through an external channel, namely to the Central Authority for External Signals and for the Protection of Individuals to whom such protection is provided under the Law - Commission for Personal Data Protection. Approved samples under the Law can be found at the following address: Adopted forms under Whistleblowers Protection Act

WHAT TO EXPECT AFTER SUBMITTING A SIGNAL?

• We will take immediate action to ensure your confidentiality. After you submit a signal, we will verify if it is credible, and if so, we will take the necessary subsequent actions to uncover the objective truth and gather all necessary evidence, including from the parties involved and the person against whom the signal is lodged while maintaining confidentiality and the privacy of your personal data.
• If necessary, we may contact you for additional information and documentation.
• After preparing a report and before the expiration of 3 months from the submission of the signal, we will contact you to provide feedback on the signal you submitted.
• When the violation is minor and does not require further subsequent actions and in the case of a repeated signal that does not contain new material information regarding the violation, correspondence regarding your signal may be terminated.
• The company considers all submitted signals of violations while adhering to the principles of confidentiality, impartiality, fairness, independence, and absence of conflicts of interest.
• The company provides protection to reporting individuals from retaliatory actions of a repressive nature that put them at a disadvantage and does not allow such actions within its organization.

YOUR RESPONSIBILITY

• You are responsible under Bulgarian legislation and Union law for any action or inaction unrelated to the submission of the signal or not necessary for the disclosure of the violation. You may be liable under the Penal Code of the Republic of Bulgaria for filing a false report.
• In case of obviously incorrect or misleading factual statements, your signal will be returned with instructions to correct the statements and a warning about the liability you bear, namely a fine of up to BGN 7,000.

INFORMATION. CHANGES TO THIS NOTIFICATION

• This notification is available on our website, namely: https://www.sunterra.eu/en/contacts ("Website"), as well as prominently displayed in our office.
• More information regarding your rights and the processing of your signals can be found on our website.
• This notification may be subject to change, with the last effective date being 05/04/2023. Any future changes or additions to the processing of personal data described in this notification that affect you will be communicated to you through an appropriate channel depending on the usual means of communication.

PERSONAL DATA

• "Santera RE" Ltd will process your personal data for the purpose of reviewing a given signal.
• Access to your personal data will be granted only to the persons responsible for reviewing signals, as well as state and supervisory authorities, in cases determined by law.