Welcome to the Whistleblowing Portal of Deutsche Telekom IT Solutions Hungary!

Legal and fair behaviour is the basis of our Company's operation. In our corporate culture, it is important to talk openly about problems and speak out against behaviour that violates our ethical standards or rules. That is why we ask if you have information about inappropriate behaviour or action, contact us as soon as possible, because we can only take appropriate steps only if we know about it.

Although the data of the whistleblowers are treated strictly confidential during the investigation, you have the option to file a report with or without name. In case a report is made anonymously, even the persons who are conducting the investigation will not be able to identify the whistleblower.

It is important that you use the reporting option in good faith and only in cases that you think the case is real. In the report, please outline the circumstances as much detailed as possible, you can also attach document, but at the same time avoid the transmitting of personal data that is not essential for the case.

1. GENERAL RULES

Deutsche Telekom TSI Hungary Kft. and Deutsche Telekom ITTC Hungary Kft.  (referred to hereinafter as “Company”) operates an internal whistleblowing system in compliance with the provisions of Act XXV of 2023 on complaints, disclosures in public interest, and related rules on reporting abuses, (commonly known as the Whistleblower Protection Act), which is intended to ensure the reporting of any violations of the rules of conduct and other corporate rules set out in the Company’s Code of Conduct, unlawful or allegedly unlawful actions or omissions, as well as information concerning other forms of abuse. 

1. 1. Whistleblower Protection

No retaliation, discrimination or unfair treatment of any kind whatsoever may be imposed on a whistleblower where they will have acted in good faith. Nor shall a whistleblower be subject to any disadvantage if the report they will have made in good faith is found to be unsubstantiated during the investigation.

In the case of lawfully filed reports, protection is due to whistleblowers under law if they have been subjected to an adverse measure and the reported action stands in breach of certain EU laws and national statutory instruments ensuring their harmonized implementation.  Such statutory instruments include the Union acts that are listed in Annex 1 and Annex 2 to Act XXV of 2023 on Complaints, Disclosures in the Public Interest and Rules Associated with the Reporting of Abuse, or the statutory provisions that ensure their implementation.

Reports filed in bad faith may incur consequences under labour, civil and criminal law.

1. 2. Parties eligible to file reports using the internal whistleblowing system

1. Employees of the employer,
2. An employee whose employment relationship with the employer has been terminated, and
3. Someone who wishes to establish an employment relationship with an employer in whose case the procedure for establishing the said relationship has commenced,
4. Individual contractors or individual firms, if they are in a contractual relationship with the employer,
5. Someone who has an ownership stake in respect of the employer, moreover anyone who is a part of the employer’s management, executive or supervisory board, including a non-executive members,
6. Someone who is subject to supervision and management by a contractor, a subcontractor, a supplier or an agent who is or has been in a contractual relationship with the employer, and regarding whom the procedure for establishing a contractual relationship with the employer will have been started,
7. Interns and volunteers who engage in activities at the employer,
8. Someone who intends to establish a legal or contractual relationship with the employer within the meaning of subsections (a), (b) or (g) and for whom the procedure for establishing such a legal or contractual relationship will have commenced, and
1. Someone whose legal or contractual relationship with the employer within the meaning of subsections (a), (b) or (g) has been terminated.

Any legal relationship in which an employee engages in activities for and under the direction of the employer in return for consideration or engages in their self-employment will constitute employment.

Employer is the legal entity (Company) that employs the whistleblower in the framework of a legal relationship intended for employment.

1. 3. Investigating Reports

Operating the Company’s internal whistleblowing system and investigating whistleblower reports falls in the scope of Compliance Management’s responsibility. Depending on the complexity of the matter, other external organisations may also be engaged in the investigation of the report. Until the conclusion of the investigation or the initiation of formal prosecution as a result of the investigation, those investigating the report may share the information regarding the content of the report and the persons involved in the report - in addition to informing the person affected by the report - with other organizational units or employees of the employer to the extent absolutely necessary for the conduct of the investigation.

Compliance Management will send whistleblowers a confirmation of the report they will have filed within 7 days of receiving their report filed in writing.

Compliance Management will investigate the allegations made in a whistleblower report within the shortest time possible under the circumstances, but within no later than 30 days from receiving the whistleblower report.

This time limit may be extended in particularly warranted cases, subject to informing the respective whistleblower thereof at the same time. In this case, they will inform the whistleblower about the expected date and the grounds for extending the investigation. The time limit for investigating a whistleblower report and informing the whistleblower in the case of an extension will be a maximum of 3 months.

During the investigation of a whistleblower report, Compliance Management will keep in touch with the whistleblower, in the scope of which it may advise the whistleblower to supplement or elaborate their report for accuracy, to clarify the facts, moreover to make additional information available.

The investigation of a whistleblower report may be waived if

(a) The report will have been filed by someone other than the person eligible to make the whistleblower report (Section 1.2),

(b) The report is a repeated report filed by the same whistleblower with content identical to the previous report,

(c) The harm to public interest or to a cogent private interest would be disproportionate to the restriction of the rights of the person concerned under the whistleblower report resulting from the investigation thereof,

(d) The investigation of the whistleblower report may also be waived if the complainant will have lodged their complaint six months after becoming aware of the action or omission which the complaint concerns.

In compliance with the requirements of fair, independent and professional proceedings, the Company will ensure that those subject to a whistleblower report are treated fairly and that the presumption of innocence is asserted in relation to them. The Company will furthermore ensure that those subject to a whistleblower report are permitted to express and provide evidence in support of their position concerning the report – including by way of their legal counsel – at any time. No information will be provided to someone subject to a whistleblower report at the time the investigation is launched in cases where immediate information provision would thwart the investigation of the respective whistleblower report.

When investigating whistleblower reports, Compliance Management will investigate and assess the relevance of the circumstances set out in the report, and the Company will instigate measures that will be appropriate for remedying the reported abuses. If a whistleblower report warrants instituting criminal proceedings, the Company will arrange for a criminal complaint to be filed.

Compliance Management will inform the whistleblower about the investigation of the report or such having been waived, along with the grounds for waiving the investigation, the outcome of the investigation of the report, and any measures instigated or planned.

The regulations for handling personal data are described in the Privacy Policy.