First Investment Bank AD (the Bank), guided by the understanding that preventive risk management and ensuring an organizational culture of trust and transparency form the basis for timely and effective issue resolution while providing the highest degree of confidentiality, has made arrangements for internal whistleblowing under the WPA.

WHO MAY SUBMIT WHISTLEBLOWER REPORTS USING THE INTERNAL CHANNELS OF THE BANK?

Any individual who has information about a violation in/by the Bank, that have become known to them during or in connection with performance of their work or office duties or in another work context, including when the relationship has been terminated at the time of whistleblowing.

WHAT MAY WHISTLEBLOWING REPORTS UNDER THE WPA CONCERN?

Whistleblowing under the WPA may concern violations of Bulgarian legislation or of EU legislation in areas under Art. 3 of WPA, related to the Bank's activities.

WHAT INFORMATION SHOULD WHISTLEBLOWER REPORTS CONTAIN?

To file a whistleblower report, a Standard Form (attached below) needs to be used approved by the central whistleblower reporting authority: the Commission for Personal Data Protection (CPDP), containing at least the following information:

1. full names, address and phone number of the whistleblower, as well as email address, if any;
2. names and position of person/s whom the whistleblower report concerns, where reporting concerns specific person/s and they are known;
3. specific details of the observed or suspected violation; place and time of the violation; description of the action itself, of the situation or other circumstances, as far as known to the whistleblower;
4. date of submission of the whistleblower report;
5. signature, electronic signature or other identification of the whistleblower.

Whistleblower reports can be accompanied by any kind of supporting information and/or contain reference to documents or persons who may confirm the report information or provide additional details.

 

HOW TO SUBMIT A WHISTLEBLOWER REPORT?

Whistleblower reports can be submitted in writing or verbally.

 

Written reports are submitted:

1. by email to: hotline@fibank.bg – the report needs to be signed with a qualified electronic signature (QES);
2. by postal mail to the following address: 1784 Sofia, 111 P Tsarigradsko Shose Blvd. The text „WPA whistleblower report“ needs to be included under the recipient's address, and the report needs to be signed by the sender.

Verbal reports are submitted:

1. by calling 02/ 800 2888, within the established working hours of the Bank;
2. at a personal meeting with a Bank's Whistleblowing Officer, agreed at the whistleblower's request. Personal meetings are arranged using the phone number or email indicated above.

Verbal reports are documented by the Whistleblowing Officer of the Bank by filling the Standard Form. Whistleblowers are offered to sign the form if they wish.

HOW WILL YOUR WHISTLEBLOWER REPORT BE PROCESSED?

• We will immediately forward it for review by competent bodies in the Bank.
• We will handle it impartially and professionally, observing the highest degree of confidentiality.
• Within 7 days of receiving your report, the Whistleblowing Officer will confirm receipt and provide you with the report’s entry date and Unique Identification Number (UIN). The UIN will be used as reference is any subsequent communication related to your report.
• In case of an established breach, we will take the necessary steps to stop it or to prevent it, if it has not started.

 

Please keep in mind:

• Anonymous whistleblower reports or reports of violations dating more than two years ago will not be considered;
• Whistleblower reports that do not fall under the scope of the WPA or whose content is manifestly implausible will not be considered;
• Whistleblower reports containing obviously false or misleading statements will be returned with a note to the whistleblower to correct their statements and a reminder of their responsibility for libel;
• In the event that the report does not meet the WPA requirements, the whistleblower will be notified to that effect and asked to bring it in line with such requirements. Failing that, within 7 days of notification the report, together with all its attachments, will be returned to the whistleblower.

IS THERE A DIFFERENCE BETWEEN A WHISTLEBLOWER REPORT AND A COMPLAINT?

• Yes, submitting whistleblower reports through the channels provided by the Bank is different from submitting complaints, related to customer care, banking products or services.
• Complaints are filed under the „Procedure for Submitting and Handling Customer Complaints“, published on the Bank’s website at www.fibank.bg. WPA whistleblower reports are filed as described above.
• Complaints refer to relations between the Bank and customers arising from existing agreements or the use of products/services.
• Whistleblower reports under WPA refer to alleged violations of Bulgarian legislation or of EU legislation in areas under Art. 3 of WPA that have become known to the whistleblower in a work context.
• The national authority for complaints is the Consumer Protection Commission. The national authority for whistleblower reporting is the Commission for Personal Data Protection.