WHISTLEBLOWER
POLICY

RoPower treats reports of potential legal violations, misconduct or irregularities seriously and with utmost care.

The main types of issues recommended for prompt reporting include:

Violations of the law in a professional context

Breaches of the Code of Conduct

Non-compliance with company policies and procedures

Concerns regarding financial statements and employee relations

Abuse

Discrimination

Corruption

Theft

Money laundering

and any inappropriate behaviour that could harm the company’s reputation — including any attempts to conceal such actions.

The company operates on the assumption that all concerns and reports submitted are made in good faith, and that they are genuine and legitimate. In this regard:

It promotes open
communication

It encourages employees and third parties to feel confident in raising concerns, questioning practices and acting ethically;

It provides secure
reporting channels

It provides employees and third parties with channels to raise concerns and to receive feedback on any actions taken as a result;

It delivers efficient
solutions

It ensures that employees and third parties receive a response to the issues they raise and are informed about the steps to take if they are not satisfied with the outcome;

It protects everyone’s
identity

It assures employees and third parties that if they raise concerns in good faith, they will be protected from any form of retaliation or victimization.

Clear and updated process

Recognizing the importance of a clear and up-to-date process for both internal reporting and the protection of whistleblowers, we have established multiple communication channels that employees and third parties can use to submit complaints or reports in accordance with Law 361/2022, as follows:

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The reporting form
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The email addresses [email protected] and [email protected]
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The Compliance Office directly

FREQUENTLY ASKED QUESTIONS

Reports can be made by individuals who have obtained information about violations of the law in a professional context. This includes, at a minimum:
  • Workers;
  • Self-employed individuals (as defined in Article 49 of the TFEU);;
  • Shareholders and members of a company’s management, leadership, or supervisory bodies, including non-executive members of the board of directors, as well as volunteers and paid or unpaid interns;
  • Any person working under the supervision and direction of a natural or legal person with whom a contract has been concluded, including subcontractors and suppliers.
Additionally, reports on legal violations can be made by persons whose employment relationships have not yet started but who disclose or report information obtained during recruitment or other pre-contractual negotiations; by those whose employment or service contracts have ended; as well as by persons who report or publicly disclose information about violations anonymously.

Violations of the law refer to actions or omissions that breach the legal provisions listed in Annex No. 2 of Law No. 361/2022, covering areas such as:
  • public procurement;
  • financial services, products, and markets; prevention of money laundering and terrorist financing;
  • product safety and compliance;
  • transport safety;
  • environmental protection;
  • radiological protection and nuclear safety;
  • food and feed safety, animal health and welfare;
  • public health;
  • consumer protection;
  • protection of privacy and personal data and the security of networks and information systems.
They also include::
  • Violations affecting the financial interests of the European Union (as referred to in Article 325 of the Treaty on the Functioning of the European Union and detailed in relevant EU measures);
  • Violations related to the internal market (as referred to in Article 26(2) of the Treaty on the Functioning of the European Union), including breaches of EU competition and state aid rules, as well as violations of internal market regulations regarding corporate taxation or mechanisms aimed at obtaining a tax advantage that defeats the object or purpose of applicable corporate tax law — which may constitute disciplinary offenses, contraventions, or criminal acts, or may otherwise undermine the intent or objectives of the law.

A report must include at least the following:
  • The whistleblower's full name;
  • The whistleblower's contact details;
  • The professional context in which the information was obtained;
  • The person concerned, if known;
  • A description of the act that may constitute a violation of the law within the public or private entity;
  • Evidence supporting the report;
  • The date and signature.
Exception: Reports that do not include the whistleblower’s name, surname, contact details, or signature may still be reviewed and addressed, as long as they present clear and credible indications of a potential legal violation.

A public-interest whistleblower can submit a report either anonymously or by disclosing their identity. From a procedural perspective, the key differences between the two types of reporting are:
  • Anonymous reports cannot be supplemented later with additional evidence or clarifications, whereas named reports allow for ongoing communication between the integrity officer and the whistleblower, enabling further clarification or support.
  • A person who reports legal violations anonymously is not eligible for protection or exemption under the provisions of Law no. 361/2022.
  • A person submitting an anonymous report cannot receive confirmation of its registration, updates on the investigation's progress, or information regarding how the case was resolved.

Irregularities Reporting Form

    Your personal details:

    *If you prefer not to disclose your identity, please note that anonymous reports may limit our ability to contact you for additional information. As a result, the investigation might not be initiated or brought to completion.

    Name

    Surname

    Date of birth

    Occupation

    Correspondence address

    E-mail address

    Phone number

    Description of the incident

    Supporting documents: accepted formats docx/pdf, max file size: 20MB

    In accordance with applicable policies, the management of irregularity reports strictly ensures the confidentiality of the individuals reporting them and expressly prohibits any form of retaliation against these individuals, including in cases where investigations do not confirm the reported issues made in good faith.

    LEGAL AND PROCEDURAL FRAMEWORK FOR REPORTING AND PROTECTING WHISTLEBLOWERS IN THE PUBLIC INTEREST - LAW no. 361/2022 on the Protection of Whistleblowers in the Public Interest

    CAREERS

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