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We comply with our obligations as prescribed by Act XXV of 2023 through the following link: https://regisztracio.panaszmester.hu//1477/hibabejelento.php
SUPPLEMENT TO THE PRIVACY POLICY
As of December 17, 2023, our company operates an internal whistleblowing system, which guarantees the following:
Within the framework of the internal whistleblowing system: (1)
only the personal data absolutely necessary for investigating the report and remedying or stopping the behaviour in question are processed.
Data that are not under the scope of paragraph (1) are promptly deleted from the internal whistleblowing system.
(2) For processing personal data within the internal whistleblowing system, we apply Section 6(2) of Act XXV of 2023 and, concerning the data of the whistleblower, Section 6(4) of the same Act.
(3) If the report pertains to a natural person, the rights to information and access guaranteed under personal data protection laws are upheld, and the personal data of the whistleblower are not disclosed to the person requesting the information.
(4) Transfer of data processed within the internal whistleblowing system to third countries or international organizations is only allowed under a legal obligation from the recipient to comply with the provisions of this law, considering the regulations on personal data protection.
(5) Within the internal whistleblowing system, personal data of the whistleblower and the person implicated in the report are known only to authorized persons. The investigators share information about the content of the report and the implicated person only as strictly necessary with other organizational units or colleagues for the investigation, beyond informing the implicated person.
(6) At the start of the investigation, the person implicated in the report is fully informed about the report, their rights concerning the protection of their personal data, and the rules for processing their data. The process ensures that the implicated person can express their viewpoint through legal representation and support it with evidence. Exceptionally, immediate information may be delayed if it would jeopardize the investigation.
(7) Paragraphs (1) and (2) are also applied to any person who may have substantial information about the contents of the report.
(8) In case of a verbal report, the whistleblower is warned about the consequences of malicious reports, the procedural rules governing the investigation, and that their identity – if they provide the necessary data for its determination – is handled confidentially throughout the investigation.
(9) Within seven days of receiving a written report in the internal whistleblowing system, the operator confirms the submission of the report to the whistleblower. The confirmation provides general information about the procedural and data handling rules under this law.
BA-HA-MA'S Ltd. fully complies with and adheres to the data protection and data management provisions of Act XXV of 2023. These provisions are recognized as binding upon ourselves.
DESCRIPTION OF THE INTERNAL WHISTLEBLOWING SYSTEM
1. Basic Terms
Employer: BA-HA-MA'S Food Wholesale and Service Limited Liability Company
Registered office, mailing address: 2120 Dunakeszi, Pallag utca 55.
2. Operation of the Internal Whistleblowing System
The employer declares that the responsible person is completely independent, impartial, and unbiased, and fully complies with the conflict of interest and impartiality.
The whistleblower may make a report in writing or verbally. Verbal reports can be made in person at the employer's registered office between 08:00 and 16:00 on business days.
The operator of the internal whistleblowing system does not use recorded systems; it documents verbal reports in writing – offering the opportunity for review, correction, and acceptance by signature – and provides a duplicate to the whistleblower. If the whistleblower makes the report in person, the operator – following the provision of information required by personal data protection regulations – records the verbal report in a durable and retrievable format or documents it in writing, offering the opportunity for review, correction, and acceptance by signature, and provides a duplicate to the whistleblower.
The operator of the internal whistleblowing system prepares a complete and accurate transcript when documenting a verbal report.
In case of a verbal report, the whistleblower is warned about the consequences of malicious reports, the procedural rules for investigating the report, and that their identity – if they provide the necessary data for its determination – is handled confidentially throughout the investigation.
The operator of the internal whistleblowing system sends a confirmation to the whistleblower within seven days of receiving a written report in the internal whistleblowing system. The confirmation provides general information about the procedural and data handling rules according to this law.
The operator of the internal whistleblowing system investigates the contents of the report in the shortest time possible as circumstances allow, but no later than thirty days from the receipt of the report.
The deadline may be extended in particularly justified cases, with simultaneous notification of the whistleblower. In this case, the whistleblower is informed about the expected duration of the investigation and the reasons for extending the investigation. The deadline for completing the investigation and informing the whistleblower should not exceed three months, even if extended.
During the investigation, the operator of the internal whistleblowing system maintains contact with the whistleblower, which may include requests for further clarification, precision, or additional information regarding the facts of the case.
The investigation may be omitted if the report is made by an unidentified whistleblower, is not made by a person authorized under Sections 20(2) and (3) of Act XXV of 2023, is a repeated report with the same content by the same whistleblower, or if the investigation of the report would not be proportionate to the public interest or substantial private interest harm to the rights of the natural or legal person (collectively: person implicated in the report) involved in the report.
(BA-HA-MA'S) Ltd evaluates the circumstances described in the report during the investigation and takes measures suitable for addressing the misconducts as specified in Section 20(1) of Act XXV of 2023. If initiating criminal proceedings is justified based on the report, actions are taken to file a complaint.
BA-HA-MA'S Ltd. informs the whistleblower in writing about the outcome of the investigation or its omission and the reasons for the omission, the results of the investigation, and the measures taken or planned.
Written notification may be omitted if the operator of the internal whistleblowing system has already informed the whistleblower verbally and the whistleblower has acknowledged the information.
