INTERNAL REPORTING OF SIGNALS IN ACCORDANCE WITH THE LAW ON PROTECTION OF PERSONS REPORTING SIGNALS OR PUBLICLY DISCLOSING INFORMATION ABOUT VIOLATIONS
PROCEDURE FOR SUBMITTING SIGNALS THROUGH THE INTERNAL CHANNEL The signal is submitted to the official responsible for reviewing signals in writing, including via email, or orally. Oral reporting of signals can be done over the phone or through other voice messaging systems, and upon the request of the reporting person, through a personal meeting within an agreed-upon timeframe (Section V, Art. 3, Para. 1 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations). To register signals, standardized forms approved by the national authority for external reporting of signals are used, containing at least the following information (Section V, Art. 3, Para. 2 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations):
Full name, address, and telephone number of the submitter, as well as an email address if available;
Names of the person against whom the signal is submitted and their position if the signal is against specific individuals who are known;
Specific information about the violation or the real danger of its occurrence, the place and period of the violation if it has occurred, a description of the action or the situation, and other circumstances known to the reporting person;
Date of signal submission;
Signature, electronic signature, or other identification of the submitter. The written signal is submitted by the submitter by completing a standardized form, stored and provided by the official responsible for reviewing signals. Oral signals are documented by completing a form by the official responsible for reviewing signals, who offers the submitter the option to sign it if desired (Section V, Art. 3, Para. 3 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations).
Any type of information sources supporting the claims in the signal and/or references to documents, including information about individuals who could confirm the reported data or provide additional information, may be attached to the signal (Section V, Art. 3, Para. 4 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations).
If the signal does not meet the requirements of Para. 1, the reporting person is notified to rectify the identified irregularities within a 7-day period from receiving the signal. If the irregularities are not rectified within this period, the signal, along with its attachments, is returned to the reporting person (Section V, Art. 3, Para. 5 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations).
Every signal is verified for its credibility. Signals that do not fall within the scope of the law and whose content does not provide grounds to be considered plausible are not considered. Signals containing obviously false or misleading statements about facts are returned with instructions to the submitter to correct the statements and the responsibility they bear for misrepresentation (Section V, Art. 3, Para. 6 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations).
A sample of the Form for registering a signal for providing information about violations under the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations can be obtained from the official responsible for receiving signals and on the website of the Commission for Personal Data Protection https://www.cpdp.bg/ (Section V, Art. 3, Para. 7 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations).
WORK WITH SIGNALS AND INTERNAL VERIFICATION
Employees responsible for reviewing signals are obliged to (Section V, Art. 4, Para. 1 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations):
Employees responsible for reviewing signals are obliged to:
Receive signals and confirm their receipt within 7 days of receiving them;
Ensure that the identity of the reporting person and any other person mentioned in the signal will be properly protected and take necessary measures to restrict access to the signal by unauthorized persons;
Maintain communication with the reporting person, requesting additional information from them and third parties if necessary;
Provide feedback to the signal submitter on the actions taken within a period not exceeding three months from the confirmation of signal receipt, or if no confirmation has been sent to the reporting person, within no more than three months from the expiration of the period in item 1;
Provide clear and easily accessible information on procedures for external reporting of signals to the competent central authority for persons wishing to submit signals and, when appropriate, to the institutions, authorities, services, and agencies of the European Union;
Document oral signals;
Maintain a register of submitted signals;
Listen to the person against whom the signal is submitted or accept their written explanations and collect and evaluate the evidence provided by them;
Provide the affected person with all gathered evidence and allow them to raise objections within a 7-day period, ensuring the protection of the reporting person;
Allow the affected person to present and indicate new evidence that may be collected during the verification;
If the facts presented in the signal are confirmed: a/ organize subsequent actions related to the signal, requesting the assistance of other individuals or units within the structure of the respective obligated entity; b/ propose to the management of the enterprise/employer to take specific measures to stop or prevent the violation in cases where it is established or there is a real danger of its future commission; c/ direct the reporting person to competent authorities when their rights are affected; d/ refer the signal to the external signal reporting body when action is needed on its part, notifying the reporting person in advance; in the case of a signal filed against the employer of the reporting person, the official responsible for reviewing the signal directs the person to simultaneously report to the external signal reporting body.
In the case of a submitted signal, the official responsible for reviewing signals must obtain a Unique Identification Code (UIC), which should be used by them to register the submitted signals with the obligated entities (Section V, Art. 4, Para. 2 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations). To obtain the UIC, the official responsible for reviewing the signal will need to provide the following information (Section V, Art. 4, Para. 3 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations):
Name and Unified Identification Code (UIC/BULSTAT) of the employer to whom the signal is submitted;
Identification data of the official responsible for reviewing the signal;
Subject of the signal/the relevant areas specified in Art. 3, Para. 1 and Para. 2 of the law;
Method of receipt/written or oral.
FOLLOW-UP ACTIONS
The employer (Section V, Art. 5, Para. 1 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations):
Based on the received signal and the suggestions of the official responsible for reviewing the signal, takes actions within its competence to stop or prevent the violation, if it has not already started;
Prioritizes, according to predefined criteria and rules, the examination of the received multiple signals for more serious violations;
Terminates the investigation: a/ when the violation for which the signal is filed is a minor case that does not require additional follow-up actions;
the termination does not affect other obligations or applicable procedures related to the violation for which the signal is filed, nor does it affect the protection under the law regarding internal or external reporting of signals;
in the case of a recurring signal that does not contain new information of essential importance for a violation for which an investigation has already been concluded, unless new legal or factual circumstances provide a basis for subsequent actions;
When data on a committed crime are established, the signal and accompanying materials are immediately sent to the prosecutor's office;
Prepares an individual report describing briefly the information from the signal, the actions taken, the final results of the investigation into the signal, and communicates it, together with the reasons, to the employee or official who submitted the signal and to the affected person while observing the obligation to protect them.
In cases where the investigation is terminated based on item 3, letters "a" and "b," the reporting person may submit a signal to the central authority for external reporting of signals (Section V, Art. 5, Para. 2 of the Internal Rules of "AZALIA I" EAD for internal reporting of signals in accordance with the Law on Protection of Persons Reporting Signals or Publicly Disclosing Information about Violations).
CONTACTS OF THE EMPLOYEE RESPONSIBLE FOR RECEIVING SIGNALS UNDER THE LAW ON PROTECTION OF PERSONS REPORTING SIGNALS OR PUBLICLY DISCLOSING INFORMATION ABOUT VIOLATIONS:
Tanya Ivanova Georgieva,
Tel. 052/358-772,
Address: Varna, St. St. Konstantin and Elena Resort, Administrative
Building,
Email for submitting signals: signals@azaliahotel.com