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Shelly

Whistleblowing Policy

Transparency and accountability in corporate management

We strive to conduct our business in accordance with applicable laws, internationally recognized standards, business practices, and established corporate policies. We recognize that a unilateral effort is not enough to create and maintain a positive and secure business environment, and that a holistic approach through joint and collaborative actions with our stakeholders is required. In accordance with the principles and requirements of the EU Whistleblowing Directive 2019/1937 and the Bulgarian Whistleblowing Act, we encourage proactive actions to report suspected wrongdoing and misconduct arising from our operations and activities, without fear of retaliation.

Who can report concerns of breaches?

Reports of irregularities may be submitted by any natural person who suspects a potential breach that they have become aware of in work-related context, such as:

  • An officer or employee, including current and formal employees, whether permanent, part-time or temporary, interns, secondees, managers and directors
  • Volunteer or intern.
  • Contractors and consultants, current and formal contractors working for the Company.
  • Shareholders, member of management or supervisory bodies in Company, and member of the audit committee of an enterprise
  • Suppliers and distributors
  • Formal employees and job candidates
  • Contractors and consultants, current and formal contractors working for the Company.
  • Any other stakeholders with a legitimate interest in the Company's operations and activities.

What concerns can be reported?

Disclosable matters may include information about:

  • Governance and Business Misconduct: Fraud, Money laundering, Bribery and Corruption, Conflict of interest, Financial irregularities, Failure to meet the legal or regulatory requirements, Public procurement and financing of terrorism.
  • Social, Human Rights and Workplace violations: Discrimination, Harassment, Health and Safety workplace (both physical and mental), infringement of Human Rights and violation of the applicable Labor laws.
  • Other Misconduct: Safety and compliance of the products and service; Customer protection, Digital security, Cuber security, Data protection, Environmental protection, and greenwashing.

How to report concerns?

Internal whistleblowing channel:

Reports of concern may be made in writing and/or verbally, as follows:

  • Via email at: breaches@shelly.com; for Shelly Europe Ltd. only dpo@shelly.com
  • In written to the address of the Company, to the attention of the Head of Human Resource: 51, "Cherni Vrah" Blvd., building 3, fl. 2-3, 1407, Sofia, Bulgaria
  • Via phone number
  • Via private meeting with eligible receiver responsible for handling reports.

Reports of concern shall be filed using an approved form by sample of CPDP, containing the following information:

  • Identification of the whistleblower: Full name, address/email address, and telephone number of the whistleblower, if available.
  • Who? Full name and job title/position in the Company of the person concerned, if the report is filed against specific persons and they are known.
  • What? Specific details about the violation or the possibility of such a violation being committed.
  • Where? The place where the violation was committed or could be committed.
  • When? The period during which the violation was committed.
  • How? A description of the violation and the circumstances surrounding it, as far as they are known to whistleblower.

Approved Form

You can download the approved form here:

Download Approved Form

We appreciate responsible disclosure of concerns for breaches, made in a good faith. Whistleblowing does not refer to reporting personal conflicts and disagreements. An investigation shall not be conducted on anonymous whistleblowing report. For more information, please read our:

Download Whistleblowing Policy