Internal whistleblowing system

The rules for operating the internal whistleblowing system are set out in Act XXV of 2023 on complaints, public interest disclosures and the reporting of abuses (hereinafter: Pkbtv.).

What can be reported?

Information on unlawful or presumably unlawful acts or omissions, or any other abuse, can be reported through the internal whistleblowing system.

Who can make a report?

A report can be made by:

1. 1employees of FX Software Zrt.,
2. 2former employees whose employment relationship with FX Software Zrt. has ended,
3. 3persons wishing to enter into an employment relationship with FX Software Zrt. for whom the hiring procedure has started,
4. 4sole proprietors and sole proprietorships in a contractual relationship with FX Software Zrt.,
5. 5persons holding an ownership interest in FX Software Zrt., and members of its administrative, management or supervisory body, including non-executive members,
6. 6persons under the supervision and direction of a contractor, subcontractor, supplier or agent that has started a procedure to establish, has, or had a contractual relationship with FX Software Zrt.,
7. 7trainees and volunteers working at FX Software Zrt.,
8. 8persons wishing to establish such a legal or contractual relationship with FX Software Zrt. for whom the procedure has started, and
9. 9persons whose such legal or contractual relationship with FX Software Zrt. has ended.

Whistleblowers may not suffer any detrimental measure as a result of their report. Their protection is governed by Chapter II, Subtitle 8 of the Act. For reports that are not anonymous, the identity of the whistleblower is treated confidentially at every stage of the investigation.

Can a report be made anonymously?

Yes, anonymous reports can be made. However, the investigation of an anonymous report may be dispensed with (pursuant to Section 22 (6) a) of the Act).

What information should be provided?

For an effective investigation, we recommend providing the following:

1. 1name
2. 2contact details (phone number, email address)
3. 3position (or former position)
4. 4any information that verifies your contractual relationship

The report must include the names of the persons and organisations concerned, a detailed description of the case and all relevant information related to it. The whistleblower must also declare that the report is made in good faith about circumstances they are aware of, or have good reason to believe are true.

How can a report be made?

Reports can be made in writing or orally.

Oral reports can be made by phone at +36/1-373-07-16 or in person. For an in-person report, please arrange an appointment by phone or email. Following information provided in line with data protection rules, the oral report is put in writing, and a copy is handed to the whistleblower, with the opportunity to check, correct and sign it. A complete and accurate record is made of the oral report.

When making an oral report, the whistleblower is informed of the consequences of reporting in bad faith, the procedural rules of the investigation, and that their identity — if they provide the data needed to establish it — is treated confidentially at every stage of the investigation.

Written reports can be submitted:

1. 1using the online report form on this page,
2. 2by email to belsovisszaelesbejelentes@fx.hu,
3. 3on paper, by placing it in the mailbox set up for reports at the registered office of FX Software Zrt.: 1066 Budapest, Weiner Leó utca 16, 7th floor.

Within seven days of receiving a written report, the operator of the system sends the whistleblower a confirmation, including general information on the procedural and data processing rules.

Information on data processing is in the Privacy Policy.

Investigation

At the start of the investigation, the operator informs the person concerned in detail about the report, their rights regarding the protection of their personal data, and the rules of data processing.

Reports are investigated within the shortest possible time, but no later than thirty days after receipt. In particularly justified cases this deadline may be extended, with the whistleblower informed of the expected date and the reasons for the extension. Even if extended, the investigation may not exceed three months.

During the investigation, the operator keeps in contact with the whistleblower and may ask them to supplement or clarify the report, clarify the facts, or provide further information.

In line with the requirement of fair procedure, FX Software Zrt. ensures that the person concerned can present their position on the report at any time — including through a legal representative — and support it with evidence. The person concerned is not informed at the start of the investigation if immediate notification would frustrate the investigation.

Who investigates the report?

Reports are investigated by a person with a law degree, who treats them as attorney-client privileged information under the applicable law and may not share them with unauthorised persons.

When can the investigation be dispensed with?

The investigation may be dispensed with if:

1. 1the report was made by an unidentifiable whistleblower,
2. 2the report was not made by a person entitled to do so,
3. 3the report is a repeated report by the same whistleblower with the same content as an earlier one, or
4. 4the harm to the public interest or an overriding private interest would not be proportionate to the restriction of the rights of the person concerned resulting from the investigation.

The operator informs the whistleblower in writing that the investigation has been dispensed with and why, within the shortest possible time, but no later than thirty days after receipt of the report.

Measures related to the report

During the investigation, the validity of the circumstances described in the report is assessed, and the measures suitable to remedy the abuse are taken. If the report justifies criminal proceedings, a criminal complaint is filed.

The whistleblower is informed in writing of the investigation or its dismissal and the reasons, the outcome of the investigation, and the measures taken or planned. Written information may be omitted if the whistleblower was informed orally and acknowledged it. If the investigation finds the report unfounded or no further action is needed, FX Software Zrt. closes the procedure and informs the whistleblower.

Consequences of reporting in bad faith

If it becomes evident that the whistleblower has, in bad faith, provided false information of decisive importance, the investigation may be closed without further measures, and:

1. 1if this indicates a criminal offence or misdemeanour, their personal data must be handed over to the authority or person entitled to conduct the proceedings,
2. 2if this conduct has caused damage or other harm to another person, their personal data must be handed over to the authority or person entitled to conduct the proceedings.

Contact

• 1066 Budapest, Weiner Leó u. 16, 7th floor
• Email: belsovisszaelesbejelentes@fx.hu
• Phone: +36/1-373-07-16