ABUSE REPORTING POLICY

I. General Provisions

1. HeziHold Ltd. (hereinafter: "HH") has established an abuse reporting system (hereinafter: reporting system) based on articles 13-16 of Act CLXV of 2013 on complaints and public interest reports (hereinafter: Complaints Act).

2. This Policy contains the rules, regulations, and guidelines for the operation of HH's reporting system.

3. The following persons entitled to report may make reports to the reporting system (hereinafter: reporter):

• active and former employees, as well as candidates under selection;
• individual entrepreneurs and individual companies in contractual relationship with HH;
• active and former owners, managing directors, as well as members under selection;
• active and former, as well as interns under selection;
• active and former, as well as contractual partners under selection (contractors, subcontractors).

4. The reporter may also proceed through a representative. If proceeding through a representative, the power of attorney must be included in a public document or a private document with full probative force.

5. The reporting system was established in such a way that the identity of non-anonymous reporters cannot be known by anyone other than those investigating the report.

Those investigating the report are obliged to keep confidential information about the content of the report and persons involved in the report until the closure of the investigation or the initiation of formal liability proceedings based on the investigation results, and they may not share them with any other organizational unit or employee of HH, except for informing the person involved in the report.

6. We inform the person involved in the report in detail about the report concerning them, the rules on the protection and processing of their personal data at the start of the investigation. In accordance with the requirements of fair procedure, we ensure that the person involved in the report can express their position regarding the report, even through their legal representative, and support it with evidence. The person involved in the report may exceptionally be informed later in justified cases if immediate notification would thwart the investigation of the report.

7. We draw the reporter's attention to the fact that HH does not investigate reports made by anonymous or unidentifiable reporters.

8. In applying this Policy:

8.1. a complaint is a request aimed at eliminating individual rights or interest violations, and its resolution does not fall under the scope of other procedures - particularly judicial or administrative procedures. The complaint may also contain suggestions.

8.2. a public interest report draws attention to circumstances whose remedy or elimination serves the interests of the community or the entire society. The public interest report may also contain suggestions.

8.3. a report made in good faith: behavior that does not violate the rights or legitimate interests of the other party. The requirement of good faith and honesty is also violated by someone whose exercise of rights conflicts with their previous behavior in which the other party could reasonably trust. For the purposes of applying this Policy, complaints and public interest reports are hereinafter collectively referred to as "reports."

8.4. a person involved in the report is a person:

• whose behavior or omission gave reason for the report, or
• who may have substantive information about the contents of the report.

8.5. HH may process personal data of the reporter and the person involved in the report provided in the report for the purpose of investigating the report, or may forward them to an external organization participating in the investigation of the report with the reporter's consent.

II. Methods of Reporting

HH accepts written reports addressed to HH's Ethics Officer:

• by electronic mail: zoltan.herczeg@hezihold.hu
• by post (Herczeg Zoltán HeziHold Ltd., 1135 Budapest, Petneházy u.55.1/11.) by registered mail

1. The reporter must declare at the time of making the report that they are making the report in good faith about circumstances they are aware of or reasonably assume to be true.

2. We hereby draw the reporter's attention to the consequences of bad faith reports, the procedural rules governing the investigation of reports, and that we treat their identity confidentially in all phases of the investigation.

III. General Rules for Investigating Reports

1. HH is obliged to investigate the report. 30 days are available for investigating the report from the date of its receipt. We may deviate from this deadline only in particularly justified cases, with simultaneous notification of the reporter. The duration of the investigation may not exceed 3 months in this case either.

2. We inform the reporter in writing about the results of the investigation and the measures taken. Investigation of repeated reports with identical content made by the same reporter, or reports made more than six months after becoming aware of the complained activity or omission, may be omitted. If the violation of public interest or compelling private interest is not proportionate to the restriction of the rights of the person involved in the report, HH may omit the investigation of the report.

3. If criminal proceedings are justified based on the investigation due to the behavior described in the report, we notify HH's managing director and HH's owners and take action regarding the filing of a complaint.

4. If the behavior described in the report is not a criminal offense based on the investigation but violates the behavioral rules established by HH, we notify HH's managing director, who may apply employer measures against the employee in accordance with the rules relating to employment.

5. If the report is not justified based on the investigation or no further action is necessary, we delete the data relating to the report within 60 days after the completion of the investigation.

6. If action is taken based on the investigation - including action due to legal proceedings or disciplinary measures against the person involved in the report - HH may process data relating to the report at most until the final closure of proceedings initiated based on the report.

IV. Investigation of Written Reports

1. We send a reasoned position regarding the written report to the reporter within 30 calendar days after the report is communicated, or at the latest within the deadline specified in III/1.

2. Based on the report - if it proves to be substantiated during the investigation - we ensure:

• restoration of the lawful or public interest-compliant state, or taking other necessary measures,
• elimination of the causes of identified errors,
• remedy of the damage caused, and
• initiation of liability proceedings if justified.

3. For the protection of the reporter, we ensure that the reporter does not suffer disadvantage due to making the report.

4. We transfer the reporter's personal data only to an authority with jurisdiction to conduct proceedings initiated based on the report, if this authority is legally entitled to handle it, or if the reporter has clearly consented to the transfer of their data. We do not make the reporter's personal data public without their clear consent.

5. If it becomes obvious that the reporter communicated decisive false information in bad faith and

• circumstances indicating the commission of a criminal offense or misdemeanor arise, we transfer their personal data to the authority or person entitled to conduct the proceedings,
• it is likely that they caused unlawful damage or other legal violation to others, we transfer their personal data to the authority or person entitled to initiate or conduct proceedings upon request.

V. Rules for Data Processing Related to Reports

1. During the report, we request the following data and information from the reporter and/or the person involved in the report:

• name;
• address, mailing address;
• if the reporter is a legal person, the registered office address and name of the legal representative;
• phone number;
• method of notification;
• description and reason for the report;
• copies and/or electronic versions of documents in the reporter's possession necessary to support the report;
• valid power of attorney for reporters proceeding through a representative;
• other data and information necessary for investigating and answering the report.

2. We process personal data of the reporter and the person involved in the report in accordance with the provisions of HH's Data Processing Policy.

VI. Information Obligation Related to Report Handling

1. We inform the person involved in the report in detail about the further handling of the report concerning them, as well as their rights regarding the protection of their personal data and the rules on processing their data at the start of the investigation.

2. In case of rejection of the report or unsuccessful expiration of the 30 calendar day response deadline prescribed for investigating the report in the Complaints Act (or the deadline specified in III/1), the reporter may turn to court.

VII. Report Registry

HH's Ethics Officer maintains a registry of reports and measures serving their settlement and resolution. The registry is stored in electronic form in a network folder accessible only and exclusively to them and those participating in the investigation. From the up-to-date registry, the current status of every report can be precisely tracked, as it contains the following information:

• date of receipt of the report;
• description of the report;
• description of the event or fact constituting the subject of the report;
• date of start of investigation;
• date of notification of the reporter;
• expected date of completion of investigation;
• description of measures serving the settlement or resolution of the report,
• date of closure of the investigation;
• result of the investigation, or reason for rejection if applicable,
• date of sending the response to the report (email or postal delivery)

We immediately delete from the reporting registry data relating to third persons not involved in the report that are not necessary for investigating the report and that cannot be processed according to the Complaints Act.