1. Purpose of the procedure
ATOM D&B sp. z o.o. provides a channel for reporting irregularities in accordance with 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, and the Polish Whistleblower Protection Act of 14 June 2024.
The purpose of the procedure is to enable employees, contractors and business partners to report potential breaches of the law, business ethics and ATOM D&B’s internal regulations in a safe and confidential manner.
2. Scope of reports
The reporting channel covers in particular:
- Breaches of public procurement regulations
- Corruption, bribery, conflicts of interest
- Money laundering and terrorist financing
- Breaches of health & safety and labour law
- Personal data protection breaches (GDPR)
- Breaches in the area of environmental protection
- Irregularities in financial and tax settlements
- Mobbing, discrimination, breaches of the code of ethics
- Other breaches of the law or internal regulations
3. How to report
Reports can be submitted via a dedicated e-mail address:
Please enter in the message subject: “Whistleblowing — report”
A report should include:
- A description of the irregularity — what happened, when and in what circumstances
- Identification of the persons or organisational units concerned (if possible)
- Evidence or references to documents (if available)
- The reporter’s contact details (optional — anonymous reports are possible)
4. Protection of the reporter
ATOM D&B guarantees full confidentiality of the report and protection of the reporter against any form of retaliation, including:
- Termination of an employment or service contract
- Being passed over for promotion
- A negative employee appraisal
- An unfavourable change of working conditions
- Exclusion from business cooperation
- Other forms of pressure or mobbing
5. Procedure for handling reports
- Step 1 — Acknowledgement: Every report will be acknowledged within 7 days of receipt.
- Step 2 — Verification: The report is verified by a designated ATOM D&B compliance officer (with confidentiality maintained).
- Step 3 — Investigation: If the report requires further action, an internal investigation is carried out.
- Step 4 — Feedback: The reporter receives information on how the report was handled within 90 days of acknowledgement (in line with the EU directive).
6. Anonymous reports
ATOM D&B also accepts anonymous reports. The reporter may use a non-identifying e-mail account (e.g. ProtonMail, Tutanota) or request that their data not be disclosed. Anonymity does not affect the obligation to handle the report.
7. External reports
Regardless of ATOM D&B’s internal channel, the reporter has the right to use external channels in accordance with Polish law:
- National Labour Inspectorate — for breaches of labour law and health & safety
- Central Anti-Corruption Bureau — for corruption
- Inspector General of Financial Information — for money laundering
- President of the Personal Data Protection Office — for GDPR
- Public Prosecutor’s Office — for criminal offences
8. Legal basis
This procedure has been prepared in accordance with:
- Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019
- The Whistleblower Protection Act of 14 June 2024 (Journal of Laws 2024, item 928)
- ATOM D&B sp. z o.o.’s internal compliance policy