Internal irregularity reporting procedure
Internal reporting of irregularities is the reporting of irregularities to company INA-Industrija nafte d.d. (hereinafter: the Company).
Pursuant to the current Act on the Protection of Persons Reporting Irregularities (Official Gazette 46/2022), the Company has adopted the Regulation on the procedure of internal reporting of irregularities and the appointment of a confidential person, which regulates the internal irregularity reporting procedure, appointment of a confidential person and his/her deputy, protection of persons reporting irregularities as well as all rights and obligations arising for the Company and the reporter of irregularities under this procedure.
What is an irregularity?
Irregularities are actions or omissions that are illegal and relate to the area of application and regulations specified in Article 4 of the Act on the Protection of Persons Reporting Irregularities (hereinafter: the Act), which are related to the performance of the Company’s activities.
Who can report irregularities?
Reporter of irregularities (whistleblower) can be any natural person who has found out about an irregularity in their work environment.
Work environment means professional activities in the public or private sector in which, regardless of the nature of those activities, persons acquire information about irregularities and in which those persons may experience retaliation if they report such irregularities, including the situations when such activity has ceased in the meantime or is just about to start or should have started.
Such activities include in particular:
- persons employed by the Company
- holders of shares and business stakes, as well as persons who are members of an administrative, management or supervisory body of the Company, including non-executive members, volunteers and paid or unpaid trainees
- persons working under the supervision and in accordance with the instructions of a contractor, subcontractor or supplier
- persons who in any way participate in the activities of the Company.
What are the conditions for the protection of whistleblowers?
A whistleblower is entitled to protection in accordance with the Act if the following conditions have been cumulatively met:
- if he/she had reasonable grounds to believe that the information reported or publicly disclosed about the irregularities was true at the time of the report or disclosure
- if the reported or publicly disclosed information on irregularities falls within the scope of the Act, and
- if he/she has filed a report in accordance with the provisions of the Act via the system of internal or external reporting of irregularities or has publicly disclosed the irregularity.
How to report irregularity?
A report may be filed with the Company in writing, or by making a verbal statement in case of a meeting with the confidential person or by e-mail to the following addresses:
– by mail to the address: INA-INDUSTRIJA NAFTE d.d., Zagreb
Avenija Većeslava Holjevca 10
10 020 Zagreb
To the attention of the confidential person
– electronically to the e-mail address: email@example.com
– or by toll-free phone number 0800 0120 on working days (Monday-Friday) from 8 AM to 11 PM.
A report should contain information on the whistleblower, information on the person and/or persons whom the report concerns, a description of the irregularity and the date of the report.
In order to be able to investigate a report more effectively, it is recommended that it also contain evidence of the irregularities being reported, which are known or available to the whistleblower.
A report can be submitted on the Reporting Form.
You can find more details about the rules of the procedure for internal reporting of irregularities in the Company here.