Reporting violations
POSCO-PWPC
POSCO-PWPC Sp. z o.o. has implemented a “Whistleblower Policy,” which defines the principles and procedures for reporting violations and internal irregularities, as well as the methods for managing such reports within the Company. The policy enables internal reporting and ensures reliable, objective, and timely follow-up of internal reports.
Types of reportable misconduct
The subject of reports may include, in particular, violations concerning:
- public procurement;
- financial services, products and markets;
- prevention of money laundering and terrorist financing;
- product safety and compliance;
- transport security;
- environmental protection;
- consumer protection;
- privacy and data protection;
- security of ICT networks and systems;
- financial interests of the State Treasury of the Republic of Poland, local authorities and the European Union;
- the internal market of the European Union, including competition and state aid rules and corporate taxation;
- Polish Labour Law and H&S regulations.
Reporting methods
Reporting a violation can be done in one of the following ways:
- via dedicated email to sygnalista@posco.com.pl ;
- in writing to the company’s address (POSCO-PWPC Sp. z o.o., ul. Innowacyjna 6; Biskupice Podgórne; 55-040 Kobierzyce) in a double envelope with the inner envelope marked “VIOLATION DISCLOSURE”.
- at the dedicated telephone number 71-774-75-03
NOTE: If a member of the management board of POSCO-PWPC Sp. z o.o. is involved in the violation, please go directly to the website available at https://www.posco.co.kr/homepage/docs/eng7/jsp/ethics/s91a3000160c.jsp
send the application to the e-mail address ethics@posco.com ; humanrights@posco.com or by phone+82-80-390-3366 ; +82-80-066-8585
Report
The report should provide a clear explanation of the subject of the report and should include at least the following information:
- the whistleblower’s personal data, including contact details;
- whistleblower status indication;
- the personal details of the subject of disclosure;
- a detailed description of the violation;
- the date and place of the violation;
- the personal data, including contact details, of any witnesses;
- indication as to any evidence in support of the violation of internal regulations or procedures;
- indication as to the alleged or existing effects of the violation.
The Company’s Management Board should ensure that adequate technical and organisational measures are in place to safeguard the confidentiality of the identity of the whistleblower, subject of disclosure, as well as other individuals mentioned in the disclosure or whose personal data have been obtained in the course of the investigation, in particular designated assistants, witnesses and whistleblower’s associates.
Confidentiality also extends to any information obtained when processing a disclosure of a violation, from which the identity of the persons specified above can be directly or indirectly inferred.
The Company’s Management Board should provide access to the personal data and information indicated in the disclosure only to the persons who have been authorised to process them, to the extent necessary for the performance of tasks related to the organisation of the receipt and review of disclosures and follow-up action.
A disclosure can only be made in good faith, invoking actual events that may constitute a violation. Only good-faith disclosures will be dealt with in a way that guarantees the confidentiality of the whistleblower and provides protection against retaliatory action.
Protection against retaliation
The Company should take steps to protect the whistleblower and designated assistant from retaliation.
Protection from retaliation will extend to a whistleblower making a disclosure in good faith.
If a disclosure is made in good faith, the Company should prohibit any retaliation against any person covered under this Policy, including against threats of or attempts at retaliatory action.
In the event that retaliatory action is discovered against persons protected under this Policy in connection with a disclosure, the Company will take immediate disciplinary action against the person or persons who committed the aforementioned retaliatory actions.
Personal data protection
The controller of the personal data processed in connection with a disclosure is POSCO-PWPC Sp. z o.o.
The whistleblower’s personal data and those of other persons indicated in the disclosure or persons whose personal data is obtained in the course of the investigation will be processed in line with the applicable laws on personal data protection, including the organisation’s internal regulations on personal data protection.
It is prohibited to disclose to third parties the personal data of the whistleblower or the subject of disclosure, unless otherwise provided by separate legislation.
The identity of the whistleblower may be disclosed on the basis of his or her express consent.
Personal data obtained as a result of a disclosure should be processed for the time necessary to complete the investigation and for the defence or assertion of claims by the organisation under the general rules of law.
The fulfilment of information obligations towards persons whose data have been obtained in the proceedings, in particular towards data subjects, may be postponed where there is a risk that prior notification may adversely affect the course and outcome of the investigation.