The WhistleSpot reporting platform serves as a communication channel for submitting internal reports concerning violations within [Name of Entity], in accordance with the scope of Law 4990/2022, as currently in force.
In addition to the WhistleSpot platform, internal reporting can be made through:
A report, whether identified or anonymous, is the act of a natural person providing information—orally, in writing or via an electronic reporting platform—concerning breaches that relate to the entity where they currently work, have worked in the past or are about to work in the future. Such breaches may involve acts or omissions that are unlawful under Union law or infringe Union rules, as defined in Law 4990/2022. Reports may include clear and substantiated information or reasonable suspicions of breaches that have occurred or are likely to occur in the future. In addition, reports may include information about attempts to conceal such breaches.
Reports are categorized into two types:
⚠️ Important: For submitting an external report to the NTA, you are advised to visit the official website of the National Transparency Authority for more information and detailed submission instructions.
The Reports Receipt and Monitoring Officer is a staff member appointed by the entity’s highest administrative body and is entrusted with at least the responsibilities laid down in the relevant provisions of Law 4990/2022, as applicable. These responsibilities include, among others:
ü Providing information on how to submit a report.
ü Receiving and recording reports concerning breaches.
ü Issuing an acknowledgment of receipt to the reporting person.
ü Managing the report and referring it to the competent bodies.
ü Ensuring the confidentiality of the reporting person's identity.
ü Monitoring the progress of the report and informing the reporting person accordingly.
📌 The appointment of an Reports Receipt and Monitoring Office does not restrict the right of the reporting person to report directly to the National Transparency Authority (NTA), especially if they have reasonable grounds to fear retaliation or if they believe the report will not be effectively followed up within the entity—such as in cases where the report concerns the Reports Receipt and Monitoring Officer themselves.
Breaches that fall within the scope of Article 4 of Law 4990/2022, as applicable, include the following:
ü Breaches of Union law, as set out in Part I of the Annex, in the following areas:
ü Breaches affecting the financial interests of the European Union, in accordance with Article 325 of the Treaty on the Functioning of the European Union (TFEU) and related Union measures.
ü Breaches relating to the internal market, including violations of Union competition rules and state aid provisions, as well as breaches related to corporate taxation and arrangements whose objective is to obtain tax advantages that defeat the object or purpose of the applicable tax law.
ü Breaches of national law, such as offences of bribery and trading in influence, as defined in the Penal Code (Articles 159, 159A, 235, 236, 237, 237A, and 396) and in Law 5090/2024 (Article 134).
⚠️ Important: According to Law 4990/2022, certain exceptions and limitations apply regarding which breaches may be reported. For details, please consult Article 5 of the Law and relevant legal provisions.
The reporting person is a natural person who discloses information on breaches that have occurred or are likely to occur in the context of their work-related activities. Protection extends to:
Persons who have acquired information on breaches in the context of their work-related activities and report them. This includes:
Individuals reporting breaches related to previous work relationships or breaches discovered during recruitment or pre-contractual stages.
This includes:
⚠️ Important: Protection for the reporting person applies under the following conditions:
Law 4990/2022 expressly prohibits all forms of retaliation against reporting people, including threats and acts of reprisal.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
Whistleblowers are protected from legal liability for acquiring or disclosing information on breaches, provided such acts do not constitute a criminal offence. If the report relates to a breach, the reporting person is not liable if they had reasonable grounds to believe that the disclosure was necessary. Furthermore, the acquisition or disclosure of trade secrets may be lawful under Law 4605/2019.
Any criminal or administrative proceedings against the reporting person are suspended until the investigation is completed. If the reporting person is involved in the breach, they may be exempted from sanctions if the report was made in good faith. Whistleblowers are not held liable for submitting reports related to breaches, unless the report contains false information knowingly, in which case general legal provisions apply.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
Whistleblowers are entitled to free legal guidance regarding procedures and available protective measures against retaliation, free legal assistance, as well as free access to psychological support.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
Whistleblowers who suffer retaliation are entitled to full compensation for any damage suffered, unless it is proven that the harmful measure was objectively justified and unrelated to the report or public disclosure. Additionally, reporting people may request reinstatement to their previous position, where possible. Dismissal due to retaliation is considered null and void in all cases.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
Any agreement or clause limiting the protection rights of the reporting person, as provided by Law 4990/2022, is null and void.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
People referred to in a report have full access to legal remedies and safeguards, including the right to a fair trial, such as the right to appeal before an impartial court, the presumption of innocence and the right of defense. Their identity is protected throughout the course of investigations related to the report or any public disclosure, in accordance with the provisions that ensure the confidentiality of the reporting person’s identity.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
There will be no consequences for the reporting person as long as the conditions set out in Law 4990/2022 are met, as described in Question 6. However, if the reporting person knowingly makes false reports or false public disclosures, they may face consequences, such as criminal liability and penalties, as their liability is not excluded under other applicable legal provisions.
📝 For more information, please refer to Law 4990/2022, contact the Reports Receipt and Monitoring Officer or consult relevant documents (e.g., the Whistleblowing Policy) of the entity.
For instructions on how to submit and track a report through the WhistleSpot platform, please follow the steps below depending on the status of the report:
is used for submitting a new report. Once you click on the icon, you will be directed to the report submission interface, where you will find an "i" icon. By selecting it, a new window will be opened with useful instructions and important updates.
is used for tracking a submitted report. Through this, you can communicate with the Reports Receipt and Monitoring Officer to receive updates on the progress of your report.⚠️ Important: For any further information contact the Reports Receipt and Monitoring Officer.