Whistleblowing - Promoting Integrity and Transparency

We uphold the highest ethical standards in all our interactions, ensuring trust and transparency with our clients, employees, and partners (contractors, subcontractors, and suppliers). Integrity is one of our core values. Seed Starter has developed a dedicated reporting channel in accordance with the provisions of Law 361/2022 regarding the protection of whistleblowers in the public interest, and EU Directive 2019/1937.

This channel is exclusively dedicated to reporting ethical violations or other irregularities, such as fraud, conflicts of interest, or behaviors that contravene the bank's internal policies, national and international legislation, and EU law that affect the public interest.

When to use this reporting channel?

• Financial crime (fraud, embezzlement, etc.);
• Corruption or conflicts of interest;
• Violation of internal regulations/national or international legislation by an employee or by a natural or legal person acting on behalf of and for Seed Starter;
• Violation of regulations regarding securities and the market (abuse of privileged information, market manipulation, dissemination of false information);
• Money laundering/terrorist financing;
• Data security, confidential information, forgery of documents, etc.;

Email address: whistleblower@seedstarter.ro

Confidentiality and Protection:

Your identity is protected! We are committed to preventing and prohibiting any form of retaliation against individuals who report legitimately.

Why is it important?

By using this channel, you contribute to protecting the integrity and values of Seed Starter and, implicitly, the BCR Group. Together, we can maintain a business environment based on ethical principles, a safe and equitable environment.

This channel is open to any natural or legal person from Romania or abroad who can report a suspicion in relation to Seed Starter, its employees, or those acting on behalf of and for Seed Starter (clients, suppliers, third parties).

Protection and Confidentiality:

Whistleblowers will not be at risk of dismissal, disciplinary or contractual sanctions, or in any other way. Their identity will be protected, even if it is found that the reported issues are not confirmed, provided that:

1. They act in good faith;
2. They believe, on reasonable grounds, that the information is correct;
3. They do not make the report in bad faith or for the purpose of obtaining a reward or personal gain;
4. They do not make the report for the purpose of exonerating themselves from any legal/procedural liability.

Nota Bene:

The mere reporting does not remove the potential guilt of the whistleblower, but they may benefit from mitigating clauses considering that they chose to report the respective facts.

Seed Starter takes seriously any false or bad-faith accusations made under this procedure and will consider them to be a serious disciplinary offense. Also, the person making such accusations will be liable according to the law/internal regulations.

If you deem it necessary, Annex 1 identifies a series of institutions that are mandated to supervise the Financial Market in Romania or the EU or that have responsibilities in the administration of Law 361/2022.