1. The obligation to establish an internal whistleblowing system:

The companies belonging to the MASTERPLAST Group, as employers (hereinafter referred to as the "Masterplast Group"), jointly operate an internal whistleblowing system to ensure lawful operation, in accordance with the Directive of the European Parliament and of the Council (EU) 2019/1937 on the protection of persons who report breaches of Union law and the Law XXV of 2023 on complaints, public interest disclosures, and the rules related to reporting abuses (hereinafter: Whistleblower Act), and the regulations governing the operation of the MASTERPLAST Group whistleblowing system. The purpose of the whistleblowing system is to investigate reported information related to unlawful or presumed unlawful acts or omissions, as well as other abuses, in accordance with the requirements set out in the relevant legislation.

Internal whistleblowing system operator: Masterplast Group

2. What can the notification cover?

According to the relevant legal provisions, information regarding unlawful or presumed unlawful acts or omissions, as well as other abuses, can be reported within the internal whistleblowing system.

The notifier is expected to make his/her notification in good faith and in accordance with the requirements of fairness and honesty. If, during the investigation of the notification, it becomes apparent that the notifier has provided false information or data in bad faith, further investigation of the notification may be waived or may lead to additional sanctions.

A person who reports information about an infringement is entitled to the maximum protection and must not suffer any retaliation or undue prejudice as a result of reporting in good faith.

3. Who can make a report?

In the internal whistleblowing system, a report can be made by:

(a) employee of the employer,

(b) an employed person whose employment relationship with the employer has been terminated, and

(c) a person who wishes to establish an employment relationship with an employer and for whom the procedure for the establishment of such a relationship has been started,

d) the self-employed person, the sole proprietor, the sole proprietorship, if it has a contractual relationship with the employer,

(e) a person who holds an ownership interest in the employer and a member of the administrative, management or supervisory body of the employer, including a non-executive member,

(f) a contractor, subcontractor, supplier or person under the supervision and control of a trustee who has started the procedure for establishing a contractual relationship with the employer, or who is or has been in a contractual relationship with the employer,

g) trainees and volunteers working for the employer,

(h) a person who wishes to establish a legal or contractual relationship with the employer within the meaning of points (d), (e) or (f) and for whom the procedure for the establishment of such a legal or contractual relationship has been initiated, and

(i) a person whose legal or contractual relationship with the employer as referred to in points (d), (e) or (f) has ceased; (f) a person whose legal or contractual relationship with the employer as referred to in points (a), (b) or (d) has ceased.

4. How to report

The notification can be made orally or in writing via the dedicated Masterplast Group interfaces:

- orally, at the notifier's option, on the dedicated telephone number +36 21/333 2052, which can also be used for sending voice messages and recording their voice,

- by post to 8143 Sárszentmihály, Árpád u. 1/A,

- via the dedicated page on the Masterplast Group website www.masterplastgroup.com, either with provided personal contact details or anonymously.

5. Failure to investigate a notification

The examination of the notification may be waived in the following cases, in accordance with the relevant provision of the legislation:

-      the notification was made by an unidentified (anonymous) notifier;

-      the notification was not made by a person entitled to do so;

-      the application is a repeat application by the same applicant with the same content as the previous application, or

-       the harm to the public interest or to an overriding private interest would not be proportionate to the restriction of the rights of the natural or legal person (hereinafter together referred to as the "person concerned") resulting from the investigation of the notification.

The Masterplast Group will also accept anonymous complaints from the companies concerned, however, in this case, the whistleblower should note that in the absence of contact details, if the information provided in the complaint is insufficient or inadequate to investigate the complaint or if the information necessary to initiate or effectively conduct the investigation cannot otherwise be obtained for any reason, the investigation may be closed without result. In addition, the system cannot send information to the notifier.

6. Investigation:

A notification received and acknowledged through the abuse reporting system and the facts contained therein will be investigated by the Whistleblowing Investigation Committee (hereinafter "the Committee") within a reasonable time, but no later than thirty (30) days after receipt of the notification. The time limit for the investigation may be extended only in particularly justified cases, in which case the whistleblower shall be informed of the expected date of the investigation and the reasons for the extension. The duration of the investigation shall not exceed 3 (three) months.

The Committee is responsible for following up and investigating allegations of abuse, determining the outcome of investigations and taking any further action on the basis of the allegation.

The Committee will contact the whistleblower via the whistleblowing system, if the possibilities exist in view of the way the contact is made, and may invite the whistleblower to complete or clarify the notification, to clarify the facts and to provide further information.

The Committee will inform the notifier in writing of the investigation or the decision not to investigate, the reasons for the decision not to investigate, the outcome of the investigation and any action taken or envisaged, where possible, in view of the manner in which the contact is made. The written information may be waived if the member of the Committee has orally informed the notifier of the above and the notifier has taken note of the information.

7. Action on a report

The Committee will assess the relevance of the information contained in the notification and, as a result of the investigation, determine whether an infringement or abuse has occurred. If the investigation establishes that an infringement or abuse has occurred, it will immediately take the necessary measures and make recommendations to the relevant department and/or manager to remedy the abuse. In this context, the Committee will, if the allegation justifies the initiation of criminal proceedings, take steps to bring charges.