whistleblowing policy

Reporting of breaches under the Act on Protection of Persons, Reporting Information, or Publicly Disclosing Information about Breaches and Directive 2019/1937 (the so-called Whistleblower Directive)

As of 04.05.2023, the new Act on Protection of Persons, Reporting Information, or Publicly Disclosing Information about Breaches (hereinafter referred to as "Whistleblowers Protection Act" or the "Act") is in force.

With the adoption of the Whistleblowers Protection Act:
-  Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law is transposed into Bulgarian law.
-  The conditions, procedure and measures for the protection of persons in the public and private sector who report or publicly disclose information about breaches of the Bulgarian legislation or acts of the European Union, which became known to them during or on the occasion of the performance of their work or official duties, or in another work context, are settled.

Most often, employees in an organization are the first to identify or receive information about such breaches. By reporting, these persons play a key role in detecting and preventing them. However, they often refrain from disclosing them because of fears of adverse consequences. In order for these persons to feel effectively protected and to prevent possible revanchism, their protection is explicitly regulated and ensured.

Pate Play Ltd. is a reliable partner and employer that promotes honesty, ethics, integrity and compliance with the rules as top priorities in its corporate culture. The availability of internal reporting in case of breaches of these rules is a prerequisite for taking timely action and building an in-house environment of security and mutual trust.

The company is an employer in the private sector with more than 50 employees, and as such, it is an obliged subject within the meaning of the Act.

In this regard, Pate Play Ltd. creates an internal channel for reporting breaches falling within the scope of the Whistleblowers Protection Act and approves internal Rules that regulate the terms and conditions for submission, receipt and handling of signals through the internal channels in the company, as well as the conditions for ensuring protection of reporting persons.

Reports may be submitted by current and former employees of the Company, freelancers, volunteers, interns, partners, shareholders, job applicants, subcontractors, suppliers, etc. The established internal channel can also be used by all other companies part of the Group of Pate Play Ltd.

Violations that fall within the scope of the Whistleblowers Protection Act and are reportable include violations of Bulgarian legislation or acts of the European Union in the field of:
-  distribution of software products;
-  consumer protection;
-  the protection of privacy and personal data;
-  the security of network and information systems;
-  financial services, products and markets and the prevention of money laundering and terrorist financing;§  breaches affecting the financial interests of the European Union;
-  infringements related to cross-border tax schemes;
-  committed a crime of a general nature;
-  violations of the Bulgarian labor legislation and other fields specified in the Act.

Reports can be submitted to Pate Play Ltd. through the following internal channels:
-  By phone: +359 88 579 8962
-  To address: Sofia, P.O. Box 1784, 159 Tsarigradsko Shose Blvd., fl. 9, to the attention of the official, receiving reports for breaches under the Whistleblowers Protection Act
-  To e-mail address: whistleblowing@pateplay.com    
-  At the request of the reporting person, a report may also be submitted through a personal meeting at the office of Pate Play Ltd. at: Sofia, 159 Tsarigradsko Shose Blvd., fl. 9, on a day and time agreed in advance between the parties.

The submission of a signal is carried out by filling in a Form for registration of a signal for submission of information about violations under the Law on Corruption and Consumer Protection in a form that can be found on www.pateplay.com, Pateplay Confluence or provided on the spot at the office of Pate Play Ltd. in Sofia, 159 Tsarigradsko Shose Blvd., fl. 9.

Alerts can also be submitted through an external channel to the Commission for Personal Data Protection (www.cpdp.bg).

Not considered are reports of breaches, which are:
-  anonymous;
-  relating to breaches, committed more than two years ago.

Any processing of personal data, carried out in connection with the submission of reports under the Whistleblowers Protection Act, shall be carried out in accordance with Regulation (EU) 2016/679 and Directive (EU) 2016/680, and when the transmission involves institutions, bodies, services or agencies of the European Union - in accordance with Regulation (EU) 2018/1725, as well as with the Personal Data Protection Act.

The Rules for internal reporting are available here:
Order for Approving Internal Reporting Rules
Internal Reporting Rules
Report Registration Form ( BG)
Report Registration Form (ENG)
Privacy Policy