ISO 9001 certificate ISO 14001 certificate ISO 37001 certificate ISO/IEC 27001 certificate ISO/IEC 20000-1 certificate
The Company's management provides the Company's Clients, Partners and their employees, as well as other interested parties, with the opportunity to report information regarding the Company or persons acting on its behalf, conduct incompatible with ethical values and standards, abuse, corruption situations or suspicions of any of these at the following mailing address.
The Company is committed to impartially and objectively investigating the reports it has received, as described above, and will treat the information it has learned confidentially during the investigation process, and will retain the information and evidence it has learned (discovered and identified) for a specific purpose after the investigation. It ensures the independence of the persons conducting the investigation and making decisions as a result. It also ensures the confidentiality of corruption reports and prevents the bona fide reporter from being disadvantaged as a result of the report.
Information about the internal whistleblowing system operated by WSH Ltd.
WSH Computer Training and Service Ltd. (hereinafter: Company) operates an internal whistleblowing system based on the provisions of the European Union Directive 2019/1937 and Act XXV of 2023 on complaints, public interest reports and rules related to the reporting of impositions.
The internal whistleblowing system and the investigation and sanctioning process within it, if justified/provable, are fully contained in the "Complaint Handling and Anti-Corruption Investigation Policy", which can be viewed without restriction at the Company's headquarters upon request. This document is a summary of this policy.
Scope
The scope of the internal whistleblowing system covers reports to the Company regarding conduct, abuse, violations or suspicions thereof that are incompatible with the laws and anti-corruption regulations, as well as the Company's ethical values and standards, incidents that violate organizational integrity and feedback on corruption risks (hereinafter collectively referred to as: corruption reports), regardless of their form, content and method.
The scope of the internal whistleblowing system does not extend to reports and incidents that fall within the jurisdiction of a legally designated, named authority, or that are subject to legal, regulatory or administrative proceedings based on statutory authority. In these cases, the Company will officially send the full content of the corruption report to the competent authority.
The Company ensures the confidentiality of corruption reports to the extent necessary for the investigation in order to protect the identity of the reporter and the persons involved in the corruption report. The Company also ensures under all circumstances that no one is disadvantaged, discriminated against or held liable during the process related to the investigation of the above corruption reports and that the legitimate interests of the reporter are not harmed.
The investigation of corruption reports - if not involved - is carried out by the employee responsible for anti-corruption compliance, with the involvement of the Company's legal representative as necessary.
Reporting and recording corruption incidents
Corruption incidents should preferably be reported to the email address compliance@wsh.hu. If the corruption report arrives at the Company in a different way, the employee who receives it will forward it to the email address compliance@wsh.hu or corruption reports received on paper (physical data carrier) to the employee responsible for anti-corruption compliance.
The recommended content elements of corruption reports are as follows:
- name of the client/external service provider/authority etc. and/or persons involved in the corruption incident,
- sales/purchase transaction, project and/or Company service identification data
- detailed description of the corruption incident/suspect, date (frequency),
- any evidence, attached documents,
- name of the reporter (if you do not wish to remain anonymous),
- reporting contact information (if you do not wish to remain anonymous).
Assignment of the person conducting the investigation
The CEO shall instruct in writing the person conducting the investigation, who is usually an employee responsible for anti-corruption compliance or, if he/she is also involved, another independent (not involved) employee designated by the CEO on a case-by-case basis or the Company's legal representative.
Investigating corruption reports
The corruption report and the information available in it are reviewed by the person investigating it (hereinafter: investigator). If the report was not made anonymously, the investigator contacts the reporter, clarifies/supplements the information recorded in the corruption report as necessary, creating as complete a picture as possible of the corruption incident or the conduct violating ethical norms and values. The meeting or consultation with the reporter is recorded. The reporter is informed that he or she may request that his or her data be treated confidentially.
In order to enforce the right to a fair trial, the investigator consults with all of the parties involved, accurately revealing the data, information, facts, evidence related to the given corruption incident and the role, activity and participation of the parties involved in the given corruption incident, as well as the intention (awareness) and background of their unlawful conduct. Informing the person involved in the corruption incident may only be delayed if immediate information would make the investigation difficult or impossible. Information about the person reporting the incident, if requested to be kept confidential, may not be disclosed to the person(s) involved in the corruption incident. Minutes are taken of the personal discussions with the persons involved.
The investigator determines the true state of affairs. He/she identifies all legal requirements and regulations set out in the Company’s regulatory environment that were violated during the implementation of the given corruption incident. The investigator treats the identity of the reporting person confidentially during the process and does not make it public.
At the end of the process, the investigator summarizes his/her findings in a report for the executive and makes recommendations for measures to eliminate the existence/continuation of the corruption incident and prevent its recurrence. If, in the investigator's judgment, immediate action is required during the investigation process to prevent or reduce the extent of an ongoing corruption incident, the investigator shall immediately inform the executive director.
Closing the investigation process
The task of the managing director is to make the relevant decisions based on the investigation report, initiate and coordinate their implementation, and monitor them. In the event of a suspicion of a criminal offense, the Company shall hand over the entire investigation file to the competent authority. If the investigation does not confirm the actual occurrence of the reported corruption incident and the suspicion of corruption is also considered unfounded, the managing director shall close the investigation without any obligation to take action. The investigation process must be completed within 30 days of receipt of the report, but in justified cases with the permission of the managing director, this deadline may be extended to a maximum of 90 days, with the simultaneous notification of the reporter.
The Company shall inform the reporter of the results of the investigation - if the corruption report is not anonymous and the contact information of the reporter is known - within 7 days of the closure of the investigation.
Document management and data management rules
The documents and their electronic files of corruption reports are accessible to the managing director, the investigator and the data subjects in terms of their own statements during the investigation of individual anti-corruption incidents, and after closure, only the managing director and the employee responsible for anti-corruption compliance for statistical analysis purposes. The Company keeps paper-based documents closed.
The Company treats the personal data of the reporter and the data subjects confidentially during the investigation of the corruption incident and during the document retention period and ensures compliance with the legal requirements for the processing of personal data. The Company has published information on the processing of personal data that it has become aware of during the handling and investigation of corruption reports and the rights of those affected by data processing on the website https://wsh.hu. The investigator is responsible for introducing the data processing information as described above at the beginning of communication with the data subjects.
If the reporting person requests confidential/closed treatment of his/her data, the employee responsible for anti-corruption compliance will place his/her personal data in a closed envelope, thus attaching it to the file of the given corruption report and anonymizing the corruption report at the same time.
If the investigation concludes with an obligation to take action (holding the employer liable, filing a criminal complaint, etc.), the Company will destroy the personal data it has acquired during the investigation of the given corruption incident within 30 days of the final conclusion of the proceedings initiated in connection with the given corruption incident. If the investigation does not confirm the actual occurrence of the reported corruption incident and the suspicion of corruption is also considered unfounded, the Company will immediately delete the personal data it has acquired in connection with the given corruption report from the file.
Data and information related to corruption reports, incidents and their investigation must be treated confidentially, they cannot be shared with others even within the Company, and they can only be used for the purpose of handling, investigating and taking action related to the given corruption incident.