Regulation on Reporting Irregularities

This policy applies to all employees of Studio Kipo Ltd.

1. Introduction and Purpose of the Policy: This policy is formulated to formalize and establish rules for detecting and disclosing irregularities within Studio Kipo and in accordance with the Company's Code of Ethics. The policy aims to enable and encourage Company Employees (permanent/ temporary contract, contractors, and subcontractors) to report observed policy violations, illegal or unethical actions by their colleagues and/or Management without fear of punishment, retaliatory actions, or harassment.

The specific objectives of this policy are:
- Encouraging timely reporting of suspected violations;
- Establishing a discrete and confidential method for escalating reports of irregularities without fear of retaliatory actions;
- Ensuring timely response from management regarding reported issues, as well as informing informants of their rights and options;
- Protecting the rights and policies of the Company and its Employees;
- Promoting a culture of transparency, integrity, and accountability;

2. Scope of the Policy: This policy is intended to empower Employees to report suspicious activities through the proper channels. Reports should not be based on rumors, hearsay, or speculation but on real knowledge of an existing problem supported by demonstrable facts. The entire staff of the Company will be protected from punishment, harassment, or disciplinary action as a result of reporting a problem, where the reporting is made in good faith and not intended to create discord or tension within existing teams.

Possible reasons for reports may include:
- All forms of financial misconduct, including fraud, corruption, bribery, or theft;
- Actions with detrimental effects on the environment and/or workplace safety;
- Any form of criminal activity;
- Improper conduct or unethical behavior detrimental to the company's ethical values;
- Non-compliance with existing directives, internal policies, and rules;
- Non-compliance with existing laws (of the Republic of Bulgaria and the European Union);
- Harassment of employees, partners, suppliers;
- Actions contributing to Company losses;
- Attempts to cover up any of the above points;

3. Definition of the term "whistleblower" in this policy: A whistleblower, as used in this policy, is any employee of the Company who has decided to report suspicious activity by colleagues, partners, suppliers, etc., which is contrary to Studio Kipo's Code of Ethics, internal policies, as well as national and European laws. Each whistleblower must know and be convinced that what they are reporting corresponds to the truth. Whistleblowers are employees who believe they need protection against harassment, retaliatory actions, and punishments and therefore have the right to decide whether they would like to remain anonymous or not.

4. Who Can Report Violations: Any Employee, partner, supplier, contractor, subcontractor, who has witnessed a violation, may share their observations and concerns through the channels mentioned in this policy. We should all strive to be as candid as possible in our observations, reports, and actions, and follow the established flow of information. Failure to report noticed but unreported violations or abuses may be construed as complicity.

4.1. Divisions of the types of whistleblowers according to this policy:
Internal whistleblowers are Employees expected to report observed irregularities by colleagues, direct supervisors, department managers, or management;
External whistleblowers are our clients, suppliers, contractors, subcontractors, etc., who may report observations of violations to senior management;

5. What Should Be Reported: Any reasonable suspicion of fraud, corruption, unacceptable behavior (according to the Company's Code of Ethics), or illegal activity involving the company or its employees. Anyone reporting irregularities bears personal responsibility for their accuracy; reports aimed at self-vindication, causing inconvenience, individually or to a team of people, gossip, and rumors will not be considered and may lead to disciplinary action.

6. To Whom to Report and the Company's Information Flow: Reports of suspected violations of the Code of Ethics and internal policies of the Company, as well as violations of the legislation of the Republic of Bulgaria and the European Union, can be submitted directly to the Manager.

7. Reporting Procedure: For timely response and resolution of the issue, the Company requires, where possible, the informant to provide as comprehensive information as possible:
- Description of the suspected violation;
- Details of where, when, and how it occurred;
- List of names of suspected Employees involved in the violation provided by the informant;
- List of names of Employees and colleagues who can provide additional information on the case;
- How the informant came across this information;
- Any, if any, perceived losses for Studio Kipo and/or our partners;
- Which policies are believed to be violated;
- Recommendations for actions by Management;
- Names of people with whom the problem was discussed;
- Date and time of report drafting and submission;
Studio Kipo undertakes to ensure the anonymity of every Employee reporting irregularities on the Company's premises. In case the Employee does not wish to remain anonymous, Management undertakes, as far as possible, to prevent retaliation or retaliatory actions.

8. Internal Processes upon Receiving a Signal of Irregularity: The Company will make the final decision on how to proceed following this policy. Management will conduct an internal investigation/audit to confirm the accuracy of the report in a timely and discreet manner. Where possible, the informant will be provided feedback and kept informed of disclosures and preventive actions decided by the Company.

The purpose of the internal investigation/audit is:
- To determine if irregularities have occurred and, if so, the severity of the violation;
- To minimize the risk of future violations of a similar nature;
- To minimize the risk of potential losses for the Company;
- To minimize the risk of damaging the Company's prestige and reputation;
Management undertakes to conduct internal investigations/audits with integrity and the necessary appropriate response. As each issue carries different weight, Management does not undertake to set specific deadlines for implementation. A large part of the investigations/audits will be conducted internally, with a selected team from Management, and where necessary, an external audit firm will be appointed. If guilt of our Employee is proven, according to this policy, the Company's Code of Ethics, or local legislation, Management reserves the right to take disciplinary action.

9. Confidentiality and Anonymity: Management fully understands that reports made in accordance with this policy contain confidential and sensitive information, and the informant has the right to choose to remain anonymous. In such a case, we undertake to consider and investigate the reported irregularity without revealing the informant's identity, as far as possible, and if the informant's anonymity does not hinder internal investigation/audit procedures.

10. Protection from Retaliatory Actions: Studio Kipo guarantees that an Employee reporting irregularities will not be subjected to retaliatory actions by the Company and Management, regardless of whether, after the investigation, the irregularity is established. In case the informant feels pursued, harassed, or isolated by colleagues, supervisors, or Management, the respective person is requested to turn to HR with their concerns and complaints, and where necessary, we will take organizational and reorganizational actions.

11. Feedback: Where appropriate, the Company will share with the informant the results of the conducted investigations/internal audits, ensuring the informant's identity remains confidential.