PwC has an Internal Reporting Procedure, according to which violations of the law referred to in art. 3 sec. 1 of the Act of 14 June 2024 on the Protection of Whistleblowers (Journal of Laws item 928; hereinafter referred to as the “Act”) in a work-related context are subject to reporting. The procedure meets the requirements of the Act, guaranteeing the confidentiality of the reports submitted. 

In the event of observing a violation, the Whistleblower has the option of filing an electronic report via the Ethics Helpline. Reports can also be filed anonymously via this channel. At the request of the Whistleblower, an oral report may also be filed during a direct meeting organized within 14 days of the date of receipt of such a report. In such a case, with the consent of the Whistleblower, the report is documented in the form of a meeting minutes reproducing its exact course. The Whistleblower, at their request, may check, correct and approve the minutes of the meeting by signing them. 

The Ethics and Business Conduct Team is a unit authorized by PwC to receive reports, as well as to take follow-up actions, including verification of reports and further communication with the Whistleblower (including requesting additional information and providing feedback to the Whistleblower). 

Within 7 days of receiving the report, the Whistleblower will be provided with confirmation of its receipt, unless they have not provided a contact address to which such confirmation should be sent. In the case of an oral report, the Whistleblower will receive confirmation of its receipt during the meeting at which they submit the report. 

A report enabling the conduct of an investigation is subject to further verification. The Team examines the report, takes follow-up actions and provides feedback no later than 3 months from the confirmation of receipt of the report or, in the absence of confirmation of receipt of the report, within 3 months from the expiry of the 7-day period from the date of submission of the report. 

No retaliatory actions or attempts or threats to apply such actions may be taken against the Whistleblower.