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  1. This Policy is adopted by the C.A. PAPAELLINAS LTD Group of companies (“CAP”) in accordance with Directive (EU) 2019/1937/EE of the European Parliament and of the Council dated October 23, 2019, on the protection of whistleblowers (hereinafter referred to as the “Directive”) and also in accordance with the Act of the Cypriot Parliament on the Protection of Persons Reporting Violations of European or Local Law, which incorporates the Directive into Cypriot Legislation, Law 6(i)/2022.
  2. Integrity has always represented a core value of CAP. In implementing this core value CAP has always provided to any person the opportunity to report possible illegal acts or irregularities that could, among other things, affect CAP’s business or reputation, without fear of recourse and could be sure that all reports will be properly investigated.
  3. The aim of this Policy is to provide protection to persons – whistleblowers, who report (“reporting person”) any suspected illegal activity and/ or misconduct, within CAP and also other activities or omissions that could affect CAP’s business or reputation (hereinafter referred to collectively as “Harmful Conduct”).

A “Breach” means an act or omission that is unlawful, in particular a violation of any legal regulation and/or internal regulation, or thwarting their object or purpose.

Information” means information, including reasonable suspicions, about actual or potential Breach that has occurred or is likely to occur at CAP.

A “Report” means the internal or external oral or written provision of Information about a Breach to the authorized person at CAP.

A “Whistleblower” means an individual who reports or discloses Information regarding Harmful Conduct which has occurred or might have occurred or regarding attempted Harmful Conduct.

An “Intermediary” means a natural person who assists the Whistleblower in reporting and whose assistance should be kept confidential.

Work context” means the work activities through which the Whistleblowers obtain Information about Harmful Conduct and for which they could be subject to retaliation if they report such information.

Retaliation” means a direct or indirect act or omission occurring in the work context that is prompted by an internal or external report or disclosure that may be detrimental to the Whistleblower.

A “Follow-up action” means any action taken by the recipient of the Report in order to assess the veracity of the allegations made in the report and, if applicable, in order to address the reported violation, including but not limited to actions such as internal investigation, hearings, prosecution and recovery of funds.


This Policy applies to Whistleblowers who have received information about a breach in a work context and have the status of an employee, intern, cooperating self-employed person, partner and person belonging to the administrative, management or supervisory body of CAP, including non-executive members, as well as volunteers, paid or unpaid interns, and all persons who work under the supervision and under the instructions of CAP’s contractors, subcontractors and suppliers.

This Policy also applies to Whistleblowers who report or disclose information about a violation obtained within the framework of an employment relationship that has ended in the meantime or to persons whose employment relationship is yet to begin, if information about the violation was obtained during the recruitment process or other pre-contractual negotiations.

Measures to protect Whistleblowers also apply to third parties who are connected to the Whistleblower and who could be exposed to harm in the Work Context (e.g. relatives and colleagues of the Whistleblower), or to legal entities that the whistleblower owns or works for or is otherwise associated within a Work Context.


This Policy applies to reports of any Harmful Conduct as defined above and particularly to reports that concern violations of EU Law and/or Cyprus law, in the following areas:

  • Safety at Place of Work
  • Corruption
  • public procurement;
  • financial services, products and markets and prevention of money laundering and terrorist financing;
  • product safety and regulatory compliance;
  • Transport safety;
  • environmental protection;
  • radiation protection and nuclear safety;
  • food and feed safety, animal health and welfare;
  • public health;
  • consumer protection;
  • protection of privacy and personal data and security of networks and information systems and
  • EU and Cyprus competition rules and state aid.

Whistleblowers who suspect that Harmful Conduct under this Policy has occurred or is about to occur have the opportunity to report their suspicions without fear of any negative consequences. A condition of protection is that the Whistleblower made the report in good faith. This protection shall not apply to the provision of fabricated Information communicated with the intent to harm another individual. Whistleblowers cannot utilize the protection either in the case of reports made with the intention of obtaining a benefit for themselves or for another person (e.g. trying to prevent non-renewal of employment, termination of employment, etc.).

Whistleblowers are eligible for protection under this Policy if:

  • they had reason to believe that the reported breach was true at the time of notification and that it fell within the scope of this Policy; and
  • have reported internally or externally in accordance with this Policy.

Any retaliation against Whistleblowers is prohibited. In particular, these retaliatory measures are:

  • unlawful termination of the employment relationship or non-extension of the employment relationship for a fixed period;
  • non – substantiated adverse evaluation of work performance or determination of merit pay.
  • reduction in salary;
  • harassment, intimidation or ostracism;
  • relocation or transfer to another job/ position;
  • failure to enable professional development;
  • change in working hours;
  • early termination or withdrawal from a contract;
  • work assignments of work outside of the corresponding position description.

CAP prefers communication in regard with this Policy through a designated impartial person and therefore has decided that its external legal advisor Mr. Christos Mitsingas will be the person to whom any Harmful Conduct will be reported to.

The designated impartial person to whom any person within the scope of this Policy can make a report (hereafter referred to as the “Authorized Person”) is:

Christos Mitsingas
Phone: 00357 22752832 – 00357 99335266
Fax: 00357 22754975
Address for sending paper mail: P.O.Box 24104, 1701 Nicosia, Cyprus

The Authorized Person will provide the Whistleblower with a confirmation of receipt of the report within 7 days from the date of its making. The Authorized Person will choose the appropriate method of providing the confirmation.

The Authorized Person may request additional information from the Whistleblower and will provide feedback to the Whistleblower. Feedback about the Follow –up action in regard with the report is provided to the Whistleblower within a reasonable period of time, which should not exceed three months in the case of a Report under this Policy.

The Authorized Person will work with affected workplaces and/or departments to investigate the Report as effectively as possible.

The Authorized Person will conduct a thorough investigation of the Report, taking into account the content of the Report, the available evidence and the possibilities of the investigation itself. The Investigation Process:

  • will be righteous;
  • will be confidential;
  • will be effective;
  • will be independent of the persons to whom the report relates;
  • will assess the sufficiency or insufficiency of the evidence to prove the truth of the report;
  • will honour the presumption of innocence.

The Authorized Person will communicate the results of his investigation to the Chief Executive Officer of CAP, who will decide, after receiving the opinion of the Authorized Person, whether to report the results to the Appropriate Authorities. Also the CEO will report to the board of CAP which shall ensure that all necessary steps are taken in order to remedy any Harmful Conduct that has occurred or may occur.

The identity of the Whistleblower will not be disclosed without his/her express consent to anyone except the Authorized Person. The same applies to any information from which the identity of the Whistleblower could be deduced, directly or indirectly. However the said Information may be disclosed in connection with investigations conducted by competent authorities or in legal proceedings.

The Whistleblower should make sure that she/he have a reasonable suspicion of the Harmful Conduct they intend to report. A mere allegation without any evidence or more detailed information is not sufficient to prove wrongdoing.

If the Whistleblower is unsure about his/her rights or the subject of the Report or does not wish to report directly to CAP, they can report directly to the Appropriate Cypriot or European Authority (“external report”).


Whistleblowers may choose to remain anonymous. Anonymous reports to the Authorized Person should include a description of the alleged Harmful Conduct with all the details available to the Whistleblower in order to allow an efficient assessment of the case and to enable remedial measures to be taken.

Whistleblowers who choose to report anonymously should consider that since their identities are not known, it would not be possible for CAP to provide them with the protection afforded by this Policy. Should their identity become known at a later stage, they are entitled to the protection afforded by this Policy.


Any processing of personal data carried out in accordance with this Policy will be done in accordance with the applicable legal regulations of the European Union and the Republic of Cyprus.

Personal data which is manifestly not relevant for the handling of a Report shall not be collected or if accidently collected, shall be deleted without delay. Also personal data collected for the Report shall be deleted within three months after the completion of the investigation of the Report. In cases where judicial or disciplinary proceedings have commenced in regard with the results of the investigation of a Report or against the Whistleblower the personal data is retained throughout these proceedings and deleted after one year from their completion.


This Policy is adopted by the Board of Directors of CAP and enters into force on the day following its publication on the internet site of CAP.