INA Group Code of Ethics
INA Group Code of Ethics (CoE) defines the fundamental values and principles of conduct of the INA Group management and employees in terms of their attitude towards work, associates, business partners and the public. The CoE also sets obligations of INA Group to secure appropriate work conditions and professional development to employees and ensure avoidance of unacceptable forms of behavior. The CoE covers a broad area of business relationships and processes and must be observed by all persons acting in the name and on the behalf of INA Group, including natural persons or legal entities who are in a contractual relationship with INA Group (business partners, consultants, suppliers, sellers, etc.). Contracts with our business partners envisage an obligation for our business partners to adhere to the CoE.
INA Group Ethics Council
E-mail: eticko.povjerenstvo@ina.hr
Telephone number: +385 (1) 64-52-454 (phone secretary available 24 hours a day/seven days a week)
Address: Av. V. Holjevca 10, P.O. Box 555, Zagreb, Republic of Croatia (obligatory note “Attn.: INA Group Ethics Council” and “Do not open”)
Internal irregularity reporting procedure
Internal reporting of irregularities refers to the reporting of irregularities to CROSCO, naftni servisi d.o.o. (hereinafter: the Company). In accordance with the applicable Act on the Protection of Persons Reporting Irregularities (“Official Gazette”, No. 46/2022), the Company has adopted the Rules on the Procedure for Internal Reporting of Irregularities and the Appointment of a Confidential Person, which regulate the procedure for internal reporting of irregularities, the appointment of a confidential person and their deputy, the protection of the whistleblower, as well as all rights and obligations arising for the Company and the whistleblower within the framework of this procedure.
What is an irregularity?
Irregularities are actions or omissions that are unlawful and relate to the scope of application and regulations referred to in Article 4 of the Whistleblower Protection Act (hereinafter: the Act), and that relate to the performance of the Company’s operations.
Who may be a whistleblower?
A whistleblower may be any natural person who becomes aware of an irregularity within their working environment. The working environment comprises professional activities in the public or private sector within which, regardless of the nature of those activities, individuals acquire information about irregularities and within which such individuals might suffer retaliation if they report such irregularities, including situations in which the activity has ceased in the meantime or is about to begin or ought to have begun.
Such activities particularly include:
- persons employed by the Company;
- shareholders and holders of equity interests, as well as persons who are members of the Company’s administrative, management, or supervisory bodies, including non-executive members, and volunteers and paid or unpaid trainees;
- persons working under the supervision and in accordance with the instructions of contractors, subcontractors, and suppliers;
- persons who in any way participate in the Company’s activities.
What are the conditions for whistleblower protection?
A whistleblower is entitled to protection under the Act if all of the following conditions are cumulatively met:
- they had reasonable grounds to believe that the information reported or publicly disclosed concerning irregularities was true at the time of reporting or disclosure;
- the reported or publicly disclosed information concerning irregularities falls within the scope of the Act; and
- they submitted the report in accordance with the provisions of the Act through the internal or external reporting system or publicly disclosed the irregularity.
How to submit a report of irregularities?
A report to the Company may be submitted in writing, verbally for the record during a meeting with the confidential person, or by electronic mail to the following addresses:
- Industrijska cesta 1, 10310 Ivanić Grad, CROSCO gatehouse, attn. Confidential Person
- Email address: povjerljivaosoba@crosco.hr
The confidential person for CROSCO d.o.o. is Tugomir Križanić.
The report should contain information about the whistleblower, information about the person and/or persons to whom the report relates, a description of the irregularity, and the date of the report. To enable a more effective examination, it is recommended that the report also include any evidence of the reported irregularities that is known or available to the whistleblower.
The report may be submitted using the Reporting Form. More detailed information on the rules governing the internal reporting procedure within the Company can be found here
Rules on the Procedure for Internal Reporting of Irregularities and the Appointment of a Confidential Person
Decision on the Appointment of the Confidential Person
Protection of whistleblowers
The Act on the Protection of Persons Reporting Irregularities entered into force on 23 April 2022 with the aim of providing effective protection to whistleblowers, including ensuring accessible and reliable channels for reporting irregularities. Please refer to the Guide for Whistleblowers issued by the Ombudsperson of the Republic of Croatia.