Internal reporting system

The company GoPay Czech, a branch of Worldline NV in Belgium, ID No.: 22177469, with its registered office at 370 01 Senovážné nám. 1736, registered in the Commercial Register maintained by the Regional Court in České Budějovice, file No. A 11596 (hereinafter referred to as "GOPAY") has implemented an internal whistleblowing system in accordance with Act No. 171/2023 Coll. on the protection of Reporters.

WHAT CAN BE REPORTED?
A Reporter may report a violation that has occurred or is about to occur at GOPAY, of which the Reporter has become aware, even indirectly, in connection with the performance of his/her work or other similar activity within the meaning of Section 2(3) of Act No. 171/2023 Coll. on the protection of Reporters. Reportable conduct may be any alleged violation of the Worldline Code of Ethics or the laws of the Czech Republic or other applicable local laws and regulations, and other misconduct.

To clarify what can be reported, we provide the following list of examples, which is only demonstrative:

• Violations of European law on the internal market (especially in the field of tax regulation, tax incentives, unfair competition);
• Infringement of the financial interests of the European Union;
• Infringement of environmental protection;
• Infringements of animal welfare and health;
• Damage to public health;
• Violations of anti-money laundering and anti-terrorist financing regulations;
• Violations of product compliance and user and consumer safety systems;
• Violations of personal data protection and privacy systems Accepting and/or offering bribery, corruption, kickbacks, negotiation in personal self- interest, unfair administration;
• Organising unfair competition, antitrust;
• Taking personal advantage of insider information (Insider trading);
• Committing theft, fraud, misappropriation of company assets;
• Behaving inappropriately such as discriminating, bullying or harassing;
• Violating human rights, including slavery and exploitative practices;
• Acting in conflict with the company’s interests;
• Money laundering or terrorist financing;
• Receiving or handling the proceeds of crime;
• Making false statements (e.g. financial);
• Doing business with parties under embargoes, sanction;
• Covering up negligent, fraudulent or other criminal activities;
• Creating or ignoring a risk to health, safety or the environment;
• and breaches to national, international and European laws.

Excluded is the reporting of confidential information, in particular information relating to national security, information subject to attorney-client privilege, information covered by medical confidentiality.

WHO CAN SUBMIT A REPORT?
Reports may be submitted by persons who perform or have performed work or other similar activities for GOPAY, in particular, by employees, job applicants, persons performing work for GOPAY on the basis of a relationship other than employment or business partners and subcontractors.

Reports can also be made anonymously.

HOW CAN REPORTS BE SUBMITTED?
Reports may be made in writing via https://worldline.integrityline.org or orally to the Whistleblowing Officer(s) listed below. If you wish to submit the report in person, the Whistleblowing Officer(s) must accept the report within 14 days of the date on which you requested to submit it in person.

WHAT IS NOT THE PURPOSE OF THE INTERNAL REPORTING SYSTEM?
The internal reporting system should not be used to make inquiries about the company, or as a means of communicating opinions about persons employed by or cooperating with GOPAY. Please also note that making a deliberately false report is an administrative offence punishable by a fine of up to CZK 50,000.

WHAT MUST THE REPORT CONTAIN?
The report must contain, at least:

• Identification of the person to whom the report relates
• Identification of the unlawful act to which the report relates in as much detail as possible

In addition, the report may include:

• Identification of the Reporter(s)
• The contact details of the Reporter(s)
• Other supporting materials and evidence

WHAT IS THE PROCESS FOR RESOLVING THE REPORT AFTER IT HAS BEEN SUBMITTED?
Once you have submitted a report using the internal reporting channel, we are obliged to acknowledge receipt of your report within 7 days of receipt. This does not apply if you expressly request that you do not wish to be informed of the receipt of the report or if this could lead to the disclosure of your identity, or if the report does not state your identity or how to contact you. A period of 30 days is subsequently set for the assessment of the report, which may be extended twice due to the factual or legal complexity of such assessment. We are obliged to inform you of any extension, and the above applies similarly.

If the need arises on the part of the Whistleblowing Officer(s), he/she may ask the Reporter, if his/her identity is known, to add to or clarify the information given in the report. However, the Reporter shall only be contacted provided that this does not result in the disclosure of his/her identity.

We will inform you of the results of the assessment of the report without undue delay in accordance with the circumstances above. We will also inform you of any further action and corrective measures as soon as they are adopted.

You also have the option of using the external reporting channel maintained by the Ministry of Justice: https://oznamovatel.justice.cz/chci-podat-oznameni/. The contact details of the relevant person at the Ministry of Justice are also listed on that page. However, only reports within the meaning of Section 2 of Act No. 171/2023 Coll. on the protection of Reporters may be submitted through the external reporting system, where the scope of unlawful acts that may be reported is defined more narrowly than under the internal reporting system of GOPAY.

WHO ARE THE WHISTLEBLOWING OFFICERS RESPONSIBLE FOR RECEIVING AND ASSESSING REPORTS?
Whistleblowing Officer(s) responsible for receiving and assessing reports are Zbyněk Eiselt, telephone +420 602 468 240, address for electronic written reports https://worldline.integrityline.org, delivery address 370 01 Litvínovice 286, Czech Republic, must be marked "do not open, whistleblowing" and Catherine Bioul, telephone +32 474 43 65 79, address for electronic written reports https://worldline.integrityline.org, delivery address: Desiré Van Hoomissenstraat 40, 2880 Bornem, Belgium, must be marked "do not open, whistleblowing".