The internal abuse reporting system of Sysman Informatikai Zrt

Sysman Informatikai Zrt. (hereinafter: Sysman Zrt.) operates an internal whistleblowing system to ensure lawful operation. The aim of the whistleblowing system is to examine information reported concerning unlawful or suspected unlawful acts or omissions, and other abuses, in accordance with the requirements set out in Act XXV of 2023 on complaints, public interest disclosures, and rules related to whistleblowing (hereinafter: Complaint Act).

Operator of the Internal Whistleblowing System: Sysman Informatikai Zrt. Whistleblower Protection Officer

Contact: BVBR@sysman.hu

2. What Can Be Reported and How to Distinguish from Other Reports

According to Section 20 (1) of the Complaint Act, information concerning unlawful or suspected unlawful acts or omissions, and other abuses can be reported in the internal whistleblowing system.

If the report does not fall within the scope of the Complaint Act, the operator of the internal whistleblowing system informs the whistleblower in writing or electronically that Sysman Zrt., another investigating body, has the authority to investigate the report. In such cases, the operator of the internal whistleblowing system will also ensure the transfer of the report or inform the whistleblower that they do not have the authority.

3. Who Can Report?

Based on Section 20 (2)–(3) of the Complaint Act, the following can make a report in the internal whistleblowing system:

• An employee of Sysman Zrt.
• A person whose employment relationship with Sysman Zrt. has ended.
• A person who wishes to establish an employment relationship with Sysman Zrt. and has initiated the process for establishing such a relationship.
• An individual entrepreneur or sole proprietor in a contractual relationship with Sysman Zrt.
• A contractor, subcontractor, supplier, or person under the supervision and direction of a person in a contractual relationship with Sysman Zrt.
• Interns and volunteers at Sysman Zrt.
• A person who wishes to establish a legal or contractual relationship with Sysman Zrt. and has initiated the process for establishing such a relationship.
• A person whose legal or contractual relationship with Sysman Zrt. has ended.

Whistleblowers must not face any adverse action due to their report. Whistleblower protection applies according to Chapter II, Section 8 of the Complaint Act.

4. How to Report

For an effective investigation, the whistleblower is advised to provide the following information:

• Name
• Position (former or applied position)
• Information related to their contractual relationship to verify the contractual relationship (for contractual parties)
• Contact details (email address, phone number)

In anonymous reports, the whistleblower may be asked to provide their name if necessary for effective investigation and if their contact details are available. If the whistleblower is unidentifiable, the investigation of the report may be omitted (Section 22 (6) a) of the Complaint Act).

Required information in the report includes the names of individuals and organizations involved, a detailed description of the incident, all relevant information, and a statement by the whistleblower affirming that the report is made in good faith based on known or reasonably believed facts.

How to Report:

• By email: BVBR@sysman.hu
• In person, by appointment, at the internal whistleblowing system operator.
• In writing, by placing the report in the designated mailbox at Sysman Zrt.’s headquarters (1037 Budapest, Montevideo utca 10. 1st floor) reception.

For electronically submitted reports, an automatic response confirming receipt will be sent, and the whistleblower will be informed of the outcome once the investigation is concluded.

Sysman Zrt. cannot be held responsible for the failure to investigate reports that do not reach the designated email address due to actions of automatically operating security software (such as antivirus or spam filters) or other technical issues. In such cases, no automatic acknowledgment of receipt will be sent.

5. Omission of Investigation

Investigation of reports may be omitted in the following cases:

• The report is made by an unidentifiable whistleblower.
• The report is not made by a person authorized under the personal scope of the Complaint Act.
• The report is a repeated submission by the same whistleblower with identical content to a previous report.
• The public interest or substantial private interest harm is not proportionate to the restriction of rights of the person affected by the report resulting from the investigation.

6. Investigation

Upon initiating the investigation, the internal whistleblowing system operator will inform the person affected by the report about the report, their data protection rights, and the data handling regulations. The attached data protection notice can be found under this information.

Sysman Zrt. ensures that the person affected by the report can present their standpoint regarding the report – either personally or through legal representation – at any time and support it with evidence. The person affected by the report will not be informed of the investigation initiation if immediate notification would thwart the investigation.

Sysman Zrt. is obligated to investigate the report within the shortest possible time permitted by the circumstances. The investigation must be completed within 30 days of receipt of the report, except in particularly justified cases, in which case the whistleblower will be informed. The investigation period must not exceed three months.

The whistleblower will be informed in writing by the internal whistleblowing system operator about the omission of the investigation and the reasons for it within the shortest possible time permitted by the circumstances but no later than thirty days after receipt of the report.

7. Actions Related to Reports

After Sysman Zrt. investigates the report, the whistleblower will be informed of the investigation results and the actions taken. If the investigation indicates that the behavior described in the report warrants criminal proceedings, a report will be filed.

If the behavior described in the report does not constitute a crime but violates Sysman Zrt.’s internal regulations or employment-related rules, Sysman Zrt. may take employer actions against the involved employee.

If the investigation finds the report unfounded or no further action is required, the procedure will be closed by Sysman Zrt., and the whistleblower will be informed.