Internal whistleblowing system of BlackBelt Technology Zrt.
1. Obligation to establish an internal whistleblowing system
To ensure its lawful operation, BlackBelt Technology Zrt. (hereinafter: BlackBelt) operates an internal whistleblowing system. The purpose of the whistleblowing system is to investigate reported information on unlawful or presumably unlawful acts or omissions and other abuses, in accordance with the requirements of Hungarian Act XXV of 2023 on complaints, public interest disclosures and rules on reporting abuses (hereinafter: Whistleblowing Act).
Operator of the internal whistleblowing system: János Facskó
+36/20-283-2220; janos.facsko@blackbelt.hu
2. What can be reported and how a report is distinguished from other reports
Pursuant to Section 20 (1) of the Whistleblowing Act, information on unlawful or presumably unlawful acts or omissions, or on other abuses, may be reported through the internal whistleblowing system.
3. Who can make a report?
Pursuant to Section 20 (2)–(3) of the Whistleblowing Act, the following persons may make a report through the internal whistleblowing system: persons employed by BlackBelt; employees whose employment relationship with BlackBelt has ended; persons wishing to enter into an employment relationship with BlackBelt for whom the procedure for establishing that relationship has started; sole proprietors and sole proprietorships in a contractual relationship with BlackBelt; persons under the supervision and direction of a contractor, subcontractor, supplier or agent that has started a procedure for establishing a contractual relationship with BlackBelt, is in a contractual relationship with BlackBelt or was in such a relationship; trainees and volunteers working at BlackBelt; persons wishing to establish a legal or contractual relationship with BlackBelt for whom the relevant procedure has started; and persons whose legal or contractual relationship with BlackBelt has ended.
Whistleblowers may not be subjected to any detrimental measure in connection with their report. The protection of whistleblowers is governed by Chapter II, Subtitle 8 of the Whistleblowing Act.
4. How to make a report
To ensure an effective investigation, the whistleblower is advised to provide the following information when making an internal report: their name, all information that can verify their contractual relationship (in the case of contractual parties), and their contact details (address).
In the case of an anonymous report, the whistleblower may be asked to provide their name – if this is essential for the effective investigation of the report and the whistleblower's contact details are available. If the report was made by an unidentifiable whistleblower, the investigation of the report may be dispensed with (pursuant to Section 22 (6) a) of the Whistleblowing Act).
The report must include the names of the persons and organisations concerned by and objected to in the report, a detailed description of the case and all relevant information related to it. The whistleblower must also declare that they are making the report in good faith about circumstances of which they have knowledge or which they have reasonable grounds to believe are true.
Ways of making a report:
– On paper, using the downloadable forms, sent to P.O. Box 629, 1539 Budapest (BlackBelt Technology Zrt.).
– Orally and in person to the operator of the internal whistleblowing system, after arranging an appointment via the contact details given above (minutes are taken of the conversation).
5. Cases in which the investigation may be dispensed with
The investigation of a report may be dispensed with in the following cases: the report was made by an unidentifiable whistleblower; the report was not made by a person entitled to do so under the personal scope; the report is a repeated report by the same whistleblower with the same content as a previous report; or the harm to the public interest or to an overriding private interest would be disproportionate to the restriction of the rights of the natural or legal person concerned by the report (hereinafter together: person concerned) resulting from the investigation of the report.
6. Investigation
At the start of the investigation, the operator of the internal whistleblowing system informs the person concerned in detail about the report, about their rights regarding the protection of their personal data and about the rules on the processing of their data. The privacy notice is included in the whistleblowing form.
In line with the requirement of fair procedure, BlackBelt ensures that the person concerned may set out their position on the report at any time – also through their legal representative – and support it with evidence. The person concerned is not informed at the start of the investigation if immediate notification would frustrate the investigation of the report.
BlackBelt is obliged to investigate the content of the report within the shortest time permitted by the circumstances. The investigation must be carried out within 30 days of receipt of the report at the latest; this deadline may be deviated from – except for reports made by anonymous or unidentifiable whistleblowers – only in particularly justified cases, with simultaneous notification of the whistleblower. The investigation may not exceed 3 months.
The operator of the internal whistleblowing system informs the whistleblower in writing that the investigation has been dispensed with and of the reasons for this, within the shortest time permitted by the circumstances, but no later than thirty days after receipt of the report.
7. Measures related to the report
After investigating the report, BlackBelt informs the whistleblower of the outcome of the investigation and the measures taken. If, based on the investigation, the initiation of criminal proceedings is justified because of the conduct described in the report, BlackBelt takes steps to initiate legal accountability.
If, based on the investigation, the conduct described in the report is not a criminal offence but violates BlackBelt's internal regulations or the rules governing employment, BlackBelt, as employer, may take employer's measures against the employee concerned.
If the investigation finds the report unfounded or no further action is necessary, BlackBelt closes the procedure and informs the whistleblower accordingly.