Compliance with legal provisions and internal regulations is the highest priority at PINOY 385 d.o.o. In case you have knowledge of violations of regulations or irregularities that threaten the public interest, please help us prevent it and file a report on irregularities pursuant to the Whistleblower Protection Act (Official Gazette 46/2022, 136/2025; hereinafter: the Act ) and in accordance with the rules of the internal whistleblowing procedure.

An irregularity is an act or omission that is unlawful and relates to the scope of European Union acts concerning, inter alia, public procurement, financial services, products and markets, and the prevention of money laundering and terrorist financing, the protection of privacy and personal data, and the security of network and information systems, as well as irregularities relating to other provisions of national law, including criminal offences under Title XXIV (criminal offences against the economy), Title XXVIII (criminal offences against official duty) and criminal offences referred to in Article 233 (embezzlement) and Article 339 (bribery of MPs) of the Criminal Code of the Republic of Croatia, if such a violation also endangers the public interest, all in accordance with Art. 4 of the Act. The irregularity must refer to those irregularities that endanger the public interest, and in the case of irregularities that endanger only the rights of individuals, including employment rights, then special regulations governing the area in which the irregularity occurred apply.

A whistleblower is a natural person who reports or publicly discloses irregularities that he or she has become aware of in his or her work environment. The employer must not take revenge, try to retaliate or threaten retaliation against the whistleblower, related persons and the confidential person and his/her deputy for reporting irregularities or public disclosure.

The internal whistleblowing procedure begins with the submission of the report to the confidential person or his/her deputy. The Confidential Person shall receive the report of irregularities and acknowledge receipt of the report within seven (7) days from the date of receipt.

A report of irregularities can be submitted in writing or orally. The written form includes any form of communication that is provided by a written record. Verbal reporting of irregularities is possible by telephone or other voice message systems and, at the request of the whistleblower, by physical meeting within a reasonable time.

• The e-mail address for submitting the application is: [email protected] .

• Mailing address: PINOY 385 d.o.o., Palmotićeva 13/1, Zagreb with the indication “for the attention of a confidential person”.

Reporting irregularities can be submitted anonymously.

The whistleblowing report contains:

• information about the whistleblower (unless it is an anonymous report),

• details of the notified body or person (if known);

• a description of the irregularities and the relevant facts and circumstances (including information on attempts to conceal such irregularities);

• Any evidence or indication of where it can be found.

• Date of application.

If the report does not have the prescribed content, the whistleblower will be invited to supplement or correct the report. In the event that the whistleblower fails to comply with the summons, the confidential person shall instruct the whistleblower to report the irregularity to the authorities authorized to act on the content of the report.

Form for submitting an anonymous report: DOWNLOAD HERE

Rules on the  procedure for internal reporting of irregularities