Schedule to Employee Concern Policy

Applicable in Hungary only

The Employee Concern Policy of the Zenitech Group, and this schedule, shall be applied both for Zenitech Hungary Kft. (3526 Miskolc, Arany János tér 1. C-D. ép. földszint) and Zenitech Consulting Zrt. (1117 Budapest, Gábor Dénes utca 4. Infopark “C” ép.).

Member states of the European Union have their own discretion in how to adopt the Whistleblower Directive (2019/1937), and in some cases to provide additional protection to the procedures pertaining to the investigation of concerns falling under the scope of this Directive.

In line with the above, the Hungarian Parliament has chosen to adapt Act XXV of 2023 on Complaints, Notifications of Public Interest and the Rules for Reporting Abuse (‘Complaints Act’) to provide such additional protections. This deviating provision is adapted with the aim of complying with the Complaints Act.

In case of any discrepancies between the provisions of this Schedule and the Policy, the provisions of the Schedule shall apply in Hungary.

Accordingly, the definitions and references in this Schedule are:

  • “reporter” – any person (including a non-employee) who wishes to report a concern
  • “company” – the employer, Zenitech Group

Stage 1 – Raising a concern

The Form to raise a concern in Hungary (for both Zenitech Hungary Kft. and Zenitech Consulting Zrt) may be requested from the below address.

The completed Form may be sent by email or via the post. However, should the reporter intend to remain anonymous, the concern may be sent in writing to the below address without the completion of the Form.

Email contact: mariann.farkas@zenitech.co.uk,
Via post: 1117 Budapest, Gábor Dénes utca 4. Infopark “C”. ép., addressed to Ms. Mariann Farkas, Head of People in Hungary (being appointed for conducting the relevant procedure).

Where the company receives an oral/verbal concern:

  • the company is obliged to take a complete and accurate record of the conversation in the form of minutes;
  • the company will inform the reporter of the consequences of concerns raised in bad faith, the procedural rules and how the reporter’s personal data may be processed as part of the process.

If the reporter is asked to attend a meeting to clarify the nature of the concern:

  • the reporter may not bring a work colleague (if they are an employee of Zenitech Group), however they may bring a legal representative; and
  • the company may also request its legal representative to be present at the meeting.

Stage 2 – Responding to the concern

Confirmation shall be provided to the reporter within 7 days of receipt of the concern, at which point:

  • the reporter shall be informed of the commencement of the procedure in line with the Complaints Act,
  • the company shall provide the notification on the processing of personal data; and
  • the company shall inform the reporter on the procedural rules (including the timescale of the completion of the proceedings).

The company aims to conclude all investigations and respond to the reporter within 30 days of receipt of the concern. However, if necessary due to the nature or complexity of the concern, the procedure cannot be closed in 30 days, the company shall inform the reporter of the extended time required. In such cases, the company aims to close such extended procedures within 3 months from the receipt of the concern.

Stage 6 – Appeal

The deadline for filing an appeal is 14 days from the receipt of the outcome of the investigation.

The appeal must be made in writing to the email or postal address mentioned above. If the reporter is asked to attend a meeting to clarify the nature of the concern:

  • the reporter may not bring a work colleague (if they are an employee of Zenitech Group), however they may bring a legal representative; and
  • the company may also request its legal representative to be present at the meeting.

The grounds for the appeal will be considered and the company will review the way the original disclosure was handled. The reporter will be informed in writing of the outcome as quickly as possible, but no later than 30 days from when the appeal was submitted.