Pursuant to Act XXV of 2023 on Complaints, Notifications of Public Interest and Rules on Notification of Abuse (hereinafter referred to as the “Whistleblowing Act”), companies with at least 50 employees are required to establish an internal whistleblowing system. To fulfill this obligation, ACG Reklámügynökség (Advertising Agency) Kft., MODAN Digital Kft. and PRO Kommunikációs (Communications) Kft. (the “ACG Group”) establish the following whistleblowing system for reporting information about unlawful or suspected unlawful acts or omissions or other breaches.

The ACG Group is committed to quality, ethical business practices and integrity. Operational efficiency and trust in the ACG Group may be compromised as a result of breaches within the organization. We therefore strive to identify and correct any potential breaches in our operations as quickly as possible.

The ACG Group's objective is to establish a whistleblowing system in relation to breaches affecting its operations that complies with the provisions of the Whistleblowing Act, while observing the provisions of Section 9(2) of Act I of 2012 on the Labor Code, and which, while protecting whistleblowers, also contributes to the elimination of breaches.

In the internal whistleblowing system, information about unlawful or presumed unlawful acts or omissions or other forms of abuse can be reported, such as:

• criminal acts,
• abuse of authority,
• attempted bribery, corruption,
• fraud,
• unfair business practices,
• breaches of contract,
• unauthorized disclosure of confidential information or personal data,
• breaches related to conflicts of interest,
• discrimination.

The internal whistleblowing system is established and operated independently by the ACG Group, without the involvement of any external contributors. In the ACG Group, the internal 2
whistleblowing system is operated by a designated internal employee (the “Designated Person”) who may not be instructed or influenced in any way by the ACG Group in the performance of his or her duties.

a) any ACG Group employee,

b) a former ACG Group employee whose employment has been terminated,

c) a future employee of the ACG Group for whom the process of establishing such a contractual relationship is underway,

d) a self-employed person, a sole proprietorship, as long as it has a contractual relationship with the ACG Group,

e) a person who has an ownership interest in the ACG Group and is a member of its administrative, management or supervisory body, including a non-managing member,

f) a contractor, subcontractor, supplier, or person under the supervision and control of an agent who has initiated, is in, or has been in a contractual relationship with the ACG Group,

g) any intern and/or volunteer working for ACG Group,

h) any person seeking to enter into a legal or contractual relationship with the ACG Group pursuant to (d), (e) or (g), in respect of whom the process of entering into such legal or contractual relationship has been initiated; and

i) any person whose legal or contractual relationship with the employer referred to in (d), (e) or (g) has been terminated.

Notifications may be made in writing:

• electronically by sending an e-mail message to whistleblowinq@acq.hu, or
• by mail to the following address: 1027 Budapest, Henger u. 2/B.

The notification can be made anonymously or by providing the name and contact details of the whistleblower. If the whistleblower does not provide their name and contact information when submitting the notification, the whistleblower acknowledges that the notification may be disregarded.

In order for the report to be investigated and the necessary action taken, the whistleblower must provide sufficient detail of the circumstances of the breach or harm that they have experienced and on which the notification is based, typically the following information:

• the organizational unit that is affected by the breach and who is affected,
• how the breach manifested itself.
• information necessary for the identification of the perpetrator of the breach, if known,
• when the breach occurred,
• whether the breach is continuing.

If there is a history of a past breach (e.g. the whistleblower has already reported the breach), this must be specified in the notification.

If the whistleblower has documents or other evidence of the breach to support their notification, they are encouraged to include them in order to ensure the effectiveness of the investigation.

ACG Group will investigate any report as soon as possible. An acknowledgement of receipt of the report will be sent to the whistleblower within 7 days of receipt thereof through the same channel used to submit the report.

Based on the report, investigation may be waived in the following cases:

a) the report was made by an unidentified whistleblower,

b) the report was not made by a person eligible to do so,

c) a repeated report by the same whistleblower with the same content as a previous report; or

d) the harm to the public interest or to a paramount private interest would be disproportionate to the restriction of the rights of the natural or legal person concerned by the report that would result from the investigation of the report.

As soon as circumstances permit, but no later than thirty days after receipt of the report, the designated person shall investigate the claims contained in the report.

In duly justified cases, the above time limit may be extended by a maximum of 3 months, provided that the whistleblower is informed at the same time. 4

The investigation of the report must include an assessment of the relevance of the circumstances alleged in the report and the adoption of appropriate measures to remedy the unlawful act, omission or breach.

The ACG Group will inform the whistleblower in writing of the outcome of the investigation and the action taken following investigation of the report.

In the course of investigating the report, ACG Group processes the personal data of the whistleblower and of the person whose action or omission prompted the report or who may have material information about the facts contained in the report.

Personal data will be treated confidentially by the ACG Group and may only be disclosed to ACG Group employees involved in the investigation of the report, the implementation of the measures and the keeping of records relating to the report.

The ACG Group processes personal data that are essential for the investigation of a report solely for the purposes of investigating the report and remedying or terminating the conduct that is the subject of such report.

Except in the case of mandatory disclosure to authorities and other bodies by law, the ACG Group does not disclose the data to third parties without prior information and consent.

The whistleblower has a right of access to his/her own statements made in the notification and during the procedure; the persons concerned who made statements during the hearings also have a right of access to their own statements.