Whistleblowing Policy

1. Purpose and Scope

VESTRONIS is committed to the highest standards of ethical conduct and legal compliance. This policy establishes the framework through which employees, contractors, partners, investors, government counterparts, and any other affected party can report concerns about actual or suspected misconduct — safely, confidentially, and without fear of retaliation.

This policy applies to all VESTRONIS operations, all project SPVs in which VESTRONIS holds a governance position, and all activities conducted by VESTRONIS employees, contractors, and platform partners.

2. What Can Be Reported

• Bribery, corruption, or improper payments to or from public officials or private parties
• Fraud, financial misappropriation, or material financial misrepresentation
• Undisclosed conflicts of interest affecting platform decisions
• Anti-competitive conduct, bid rigging, or procurement manipulation
• Violations of labour rights or health and safety standards
• Environmental non-compliance or material environmental breach
• Harassment, discrimination, or abuse of any kind
• Data protection breaches or unauthorised use of personal data
• Procurement irregularities or breach of IFI integrity requirements
• Retaliation against any person for making a whistleblower report

3. How to Report

Restricted email (governance oversight only): [email protected] — accessible exclusively to designated senior governance oversight personnel, not accessible to operational management.

Online ethics form: Via the Ethics and Whistleblower form on the VESTRONIS Contact page at vestronis.com/contact/.

Anonymous submission: Both channels accept fully anonymous reports.

4. Non-Retaliation Commitment

VESTRONIS strictly prohibits retaliation of any kind against any person who submits a good-faith whistleblower report — regardless of outcome or whether the concern is ultimately substantiated. Retaliation is itself a reportable misconduct under this policy.

5. Confidentiality

The identity of any identified reporter will be kept strictly confidential and will not be disclosed beyond the governance oversight function without the reporter's explicit consent — except where required by applicable law. Anonymous reports are investigated on the same basis as identified reports.

6. Investigation Process

All reports are acknowledged within 5 business days where contact information has been provided. The governance oversight function assesses every report within 10 business days and initiates a structured investigation where warranted. The reporter receives status updates within 20 business days of submission.

7. Regulatory Alignment

This policy is aligned with the EU Whistleblower Protection Directive (Directive 2019/1937), applicable local legislation in VESTRONIS markets, and EBRD and IFC integrity requirements. Concerns involving EBRD or EIB co-financed projects may additionally be reported to the relevant IFI accountability mechanism.

8. Contact

Ethics reporting (governance oversight only): [email protected]
General governance enquiries: [email protected]
Post: Attention: Governance Oversight, VESTRONIS, Str. Agim Ramadani, C3, No. 2, 10000 Prishtina, Kosovo.