Whistleblowing Notice

Anyone who becomes aware of a possible violation of the law, internal regulations or market standards in connection with and after the performance of duties under a contract, function or service and subsequently.

A notification can also be submitted by persons who seek employment or cooperation with the Bank at the recruitment or pre-contract negotiation stage.

Notices may relate to omissions or acts that are illegal or that are intended to circumvent the law, and relate, among other things, to:

• Bribery and corruption;
• Financial services and products;
• Money Laundering and Financing Terrorism;
• Consumer protection;
• Violation of the protection of privacy and personal data;
• Security of information and communication networks and systems
• Violation of Internal Regulations or policies and procedures;
• Violation of the principles of the Code of Ethics or other Codes of Conduct;
• Fraud;
• Violation of the recommendations of supervisory and control authorities;
• Bullying;
• Sexual misconduct;
• Harassement;
• Insider trading or market manipulation;
• Other illegal or improper behaviors or practices.

Yes, we guarantee confidentiality and anonymity to the Whistleblower.  
The whistleblower's data, if provided, will remain confidential and will only be available to the relevant persons.
In the case of anonymous reports, if the identity of the Whistleblower can be identified from the content of the report, we will remove this information before taking further steps.
The whistleblower must not suffer any adverse consequences as a result of the report, e.g. termination of the contract or reduction of salary.

Personal data, if obtained from the Whistleblower, is processed only for the purpose of evaluating the relevance and resolution of a specific Report, the legal basis for the processing of personal data is compliance with a legal obligation under the Law no. 361/2022 on the protection of whistleblowers in the public interest.

The personal data collected will not be passed on to third parties, only the relevant persons are the recipients. Personal data will be archived for a period of 5 years from the date of receipt of the notification. After the 5 years period, the reports will be deleted no matter the way they were created.

 Read more about the processing of personal data

If you are a client and want to contact us in another matter, please write to us at the following email address: bucharest@pkobp.pl

The Whistleblower will receive a written confirmation of receipt of the report, no later than 7 working days from the date of receipt. At the same time, the Whistleblower will be informed whether or not their report falls under the definition of a notification under the Whistleblower Protection Act and what rights and obligations they have in this process. The information provided will be treated as strictly confidential.

The designated person will proceed during the investigation in such a way as not to disclose the identity of the Whistleblower. Throughout the investigation, the identity of the Whistleblower will be known only to the relevant persons. In the event that it is not possible to continue the investigation without disclosing the identity of the Whistleblower to other persons, the designated person will inform the Whistleblower of this and will request their explicit consent to this procedure.

This does not apply in cases where the identity of the Whistleblower is requested by public authorities. However, the designated person must notify the Whistleblower of this fact in advance, together with the reasons for which they are obliged to provide information about their identity, and allow the Whistleblower to comment on the provision of information.

The investigation will then assess the justification of the Notification and other decisive facts. The designated person shall then notify the Whistleblower in writing of the results of this assessment within 30 days from the date of receipt of the Report. If the case is factually or legally complex, the designated is required to inform the Whistleblower within a reasonable time, not exceeding 3 months or, in justified cases, 6 months from receipt of the report, as well as whenever there are developments in the follow-up actions, unless such information could jeopardize their conduct. In such cases, the designated person must always inform the Whistleblower of this extension and of the specific reasons for it.

According to the Whistleblower Protection Act, a report can also be made through an external Whistleblowing system. In Romania the competent authority that can receive, send feedback, and follow up on integrity alerts and, where appropriate, are:

1. The National Bank of Romania (BNR) – for matters related to banking supervision and regulation (bnr.ro)
2. The National Integrity Agency (ANI) – for matters related to integrity, conflicts of interest, or incompatibilities (integritate.eu)

Whistleblowers who report in good faith are protected against any form of retaliation, in accordance with Law no. 361/2022 on the protection of whistleblowers in the public interest.