Whistleblowing policy and procedures

This Whistleblowing Policy has been developed in compliance with the applicable regulatory framework. It adheres to the provisions of the Bank of Greece Governor’s Act 2577/9.3.2006, which sets out the “Framework of operational principles and criteria for the evaluation of the organisation and Internal Control Systems of credit and financial institutions and the relevant powers of their management bodies”. Furthermore, it aligns with Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law, as incorporated into Greek legislation by Law 4990/2022 (Government Gazette A’ 210/11.11.2022).

One of our core principles is to foster mutual trust between the Bank and its customers. Transparency in our relationships is essential for maintaining high ethical standards, which strengthen the integrity and success of our institution. In this context, the Bank actively encourages the reporting of any suspected professional misconduct, breaches of the applicable legislation or European Union Acts, violations of Internal Policies, the Bank’s Code of Conduct, or any other unethical or illegal actions by employees.

Activities/offenses for which reports can be submitted

Indicatively and not restrictively, reports may concern:

• Fraud

• Forgery

• Breaches of Anti-Bribery and Corruption Policy provisions

• Breaches of anti-money laundering processes

• Acts affecting the purpose and reputation of the Bank

• All kinds of harassment (e.g. sexual, racial, religious, gender identity etc.), as well as abuse of power

• Breaches of the Bank’s  Code of Conduct

By submitting a report of suspected misconduct, individuals demonstrate responsibility and honesty, reinforcing the Bank’s commitment to integrity and ethical conduct. All reports will be treated with strict confidentiality, and the Bank will ensure that a fair, thorough, and impartial investigation is carried out.

Ways of anonymously or named reporting violations:

In paper form to the following address: Head Office of ProCredit Bank (Bulgaria) EAD, 26 Todor Alexandrov Blvd., Sofia, P.C.1303

By e-mail to ethic_signals@procreditbank.bg

Important Notes:

• The whistleblowing process, including ethical whistleblowing, is distinct from filing complaints about products, services, or customer service. If you wish to make a complaint regarding a product or service, please email complaints@procreditbank.bg or contact our call center: *7000 / +359 700 1 70 70 (when dialling from abroad).

• Reports that do not fall within the scope of the applicable legislation or whose content does not provide sufficient grounds to be considered credible will not be treated as whistleblowing reports.