1. Purpose
1.1.
Fameline Holding Group Limited, together with its subsidiaries and affiliated companies (collectively referred to as the “Group”) is committed to maintaining the highest standards of transparency, integrity and accountability. In line with the Group’s commitment to maintaining business integrity and upholding the highest ethical standards, all employees of the Group (the “Employees”) should feel empowered to report any concerns if they believe misconduct has occurred.
1.2.
The Group will thoroughly investigate any genuine and reasonable concerns related to suspected misconduct within the Group and will ensure that no Employee faces discrimination or adverse treatment for raising such concerns. This protection applies irrespective of whether the reported concerns ultimately prove to be substantiated, provided the Reporting Person had reasonable grounds to believe the information was true at the time of reporting.
1.3.
This Protected Disclosure (“Whistleblowing”) Policy (the “Policy”) outlines the framework and guidelines for Reporting Persons (as defined below) to: (i) report any Relevant Wrongdoing (as defined below) within the Group of which they become aware; (ii) receive feedback and have their report handled with confidentiality and integrity through a thorough investigation and assessment; and (iii) be protected from retaliation when making a Protected Report (as defined below), with the assurance of strict confidentiality.
1.4.
The present Policy shall be subject to periodic review and may be amended from time to time.
2. Scope
2.1.
This Policy has been developed and reviewed in accordance with Law 6 (I) of 2022 (the “Law”), which implements Directive (EU) 2019/1937 on the protection of individuals who report breaches of Union law as well as provisions for the protection of individuals reporting breaches of national law. This Policy applies to all Employees (permanent, temporary and contract), former employees, job applicants, consultants, contractors, suppliers, shareholders, directors, trainees, volunteers, and any other persons who acquire information on breaches in a work-related context with the Group.
3.
Related Policies
3.1.
This Policy should be read in conjunction with:
(a)
Employee Handbook (as amended from time to time);
(b)
The “Protection to Whistleblowers Guide to Employees” published by the Ministry of Justice and Public Order, as amended from time to time, available on the ministry’s website at: www.mjpo.gov.cy
4.
Definitions
4.1.
For the purposes of this Policy:
(a)
“Reporting Person (Whistleblower)” means an individual who reports information on breaches acquired in a work-related context.
(b)
“Relevant Wrongdoing” means acts or omissions that:
(i)
constitute a criminal offence (including corruption or fraud);
(ii)
breach obligations under national or EU law;
(iii)
breach the Group’s internal policies (including the Anti-Bribery and Corruption Policy);
(iv)
endanger the health or safety of individuals;
(v)
cause damage to the environment; or
(vi)
involve the concealment or attempted concealment of any of the above.
5.
Making a Protected Report – Reporting Channels
5.1.
Reporting channels
5.1.1.
To be protected under the Law as outlined in this Policy, a Reporting Person must report any Relevant Wrongdoing using one of the following methods:
(a)
Through Internal Reporting Channels.
(b)
External Reporting Channels.
(c)
By Public Disclosure.
5.1.2.
Reports must be made in good faith and based on reasonable grounds, but the Reporting Person is not required to prove the truth of the allegations.
5.2.
Internal Reporting Channels
5.2.1.
Reporting Persons are encouraged to use the Internal Reporting Channels as their primary point of contact.
5.2.2.
Internal reports may be submitted in writing to the Legal Department / Group Legal Director via email, telephone or in person.
5.3.
External reporting
5.3.1.
Whistleblowers may report to the Cyprus Independent Authority Against Corruption or any other competent national or EU authority designated under applicable law, if internal reporting is not feasible or effective.
6.
Public Disclosure
6.1.
Whistleblowers may publicly disclose information if:
(a)
They first reported internally and externally without appropriate action taken within the prescribed timeframe.
(b)
They have reasonable grounds to believe the breach may pose an imminent or manifest danger to the public interest, or there is a high risk of retaliation or a low prospect of the breach being effectively addressed.
7.
Protection Against Retaliation
7.1.
The Group strictly prohibits any form of retaliation against individuals who report breaches in good faith. This includes dismissal, disciplinary action, threats or any other detrimental treatment related to the report. Retaliation includes, but is not limited to, dismissal, suspension, demotion, loss of promotion, negative performance assessments, harassment, discrimination, intimidation, blacklisting, or any other unfair treatment.
8.
Confidentiality
8.1.
All reports will be handled with strict confidentiality. The identity of the Whistleblower will not be disclosed unless:
(a)
the Whistleblower explicitly consents to that;
(b)
the disclosure is a necessary and proportionate obligation imposed by EU or national law, in the context of investigations by national authorities or judicial proceedings, inter alia, with a view to safeguarding the rights of defence of the person concerned.
8.2.
Before revealing the Whistleblower’s identity, the internal reporting channels must inform the Whistleblower in advance, unless doing so would interfere with investigations or legal proceedings. They must also provide a written explanation of why confidential information is being disclosed.
9.
Record Keeping
9.1.
The Group shall keep records of every report received, in compliance with the confidentiality requirements.
9.2.
If a Whistleblower reports something using a recorded phone line or voice messaging system (with their consent), the report can be documented by:
(a)
recording the conversation in a way that can be stored and accessed later; or
(b)
writing a complete and accurate transcript of the conversation.
9.3.
If the report is made through an unrecorded phone line or voice messaging system, the conversation must be documented as an accurate transcript.
9.4.
If the report is made in person, and the Whistleblower agrees, the meeting must be documented by either:
(a)
recording the conversation in a storable and accessible format; or
(b)
writing complete and accurate minutes of the meeting.
9.5.
In all cases, the Whistleblower must be given the chance to review, correct, and sign the meeting minutes.
9.6.
Personal data collected during the reporting process will be retained only for as long as necessary and proportionate to comply with legal obligations, conduct investigations, or pursue disciplinary or judicial proceedings, and in any event in accordance with applicable data protection laws, unless legal or disciplinary proceedings are initiated, in which case data will be retained for the duration of those proceedings and deleted one year after their conclusion.
10.
Review of Policy
10.1.
The Policy will be reviewed annually by the Legal Department / Group Legal Director to ensure compliance with legal requirements and its effectiveness in promoting a culture of openness and accountability.
10.2.
In case of any questions regarding this Policy, the below should be contacted:
Carolina Panagiotou-Monoyiou, Group Legal Director at c.monoyiou@fameline.com.cy & legal@fameline.com.cy
Adamos Seraphides, CEO
10th of January 2026