**Whistleblowing and Complaints Management Policy

(Reporting of Breaches of EU Law)**

The LIFECHECK Group implements a Whistleblowing and Complaints Management Policy for the reporting of breaches of European Union law and has established a mechanism that ensures the support and protection of individuals who, in good faith, submit reports or complaints, as well as the effective handling of such reports and complaints, while safeguarding their confidentiality in accordance with applicable legislation.

Reports shall be submitted to the Reports Receipt and Monitoring Officer at the following email address: [email protected].

Whistleblowing and Complaints Management Policy

1. Definitions

Group: The entities comprising the LIFECHECK Network of Diagnostic Laboratories and Polyclinics.

Policy: Refers to this Whistleblowing and Complaints Management Policy.

2. Scope of Application

The reporting/complaints procedure is addressed to:
(a) Members of the Group’s Management, the management bodies of the entities comprising the Group, and executive management staff of the Group.
(b) Group personnel.
(c) The Group’s customers and suppliers, as well as any third party cooperating with the Group.
(d) Any third party having knowledge of or evidence relating to irregular or unlawful actions concerning the Group.

3. Purpose of the Policy

This Policy defines the principles and framework for the receipt, processing, and investigation of reports/complaints concerning irregularities, omissions, or other criminal or unlawful acts.
It aims to establish a mechanism suitable for:
(i) supporting and protecting individuals who, in good faith, submit reports or complaints, and
(ii) ensuring the effective management of reports and complaints, while safeguarding their confidentiality in accordance with applicable legislation.

4. Subject Matter of Reports/Complaints

Reports/complaints must be based on a sincere and reasonable belief that a criminal offense, misconduct, or violation has occurred or may occur.
The submission of reports by employees, associates, suppliers, and customers of the Group regarding suspicious incidents or serious irregularities is encouraged.

5. Protection of the Reporting Person and the Reported Person

The Group emphasizes the importance of good faith in reporting and complaints.
It protects individuals who submit reports or complaints in good faith from retaliation, discrimination, or adverse treatment. If a report is not substantiated, no consequences shall arise for the reporting person.

Furthermore, if the reporting person has participated in the reported act, their contribution to the identification of the irregularity shall be taken into account.

Reported persons have the right to be informed of the allegations against them, unless such notification would obstruct the investigation. In such cases, informing the persons concerned by the report/complaint may be postponed until the relevant risk ceases to exist.

6. Reporting/Complaint Submission Procedure

Reports shall be submitted to the Reports Receipt and Monitoring Officer at [email protected].
Other forms of expressions of dissatisfaction shall not be considered official reports or complaints.

Reports/complaints should include detailed information such as facts, dates, documents, locations, and the reasons for submission. Evidence is not required; however, the provision of as much information as possible is encouraged.

7. Handling of Reports/Complaints

The Reports Receipt and Monitoring Officer maintains a file for each report/complaint containing detailed information. The Officer assesses the seriousness and credibility of the report and informs Group Management accordingly.
The investigation must be completed within thirty (30) days, and any delay must be duly justified. In the event of a conflict of interest, the relevant member of Management shall abstain from the investigation.

The Reports Receipt and Monitoring Officer of the Group:

(a) Immediately informs the reporting person of the receipt of the report/complaint by providing a relevant acknowledgment of receipt (electronic), and informs them of the outcome of the investigation upon its completion.

(b) Conducts an initial assessment of the seriousness and credibility of the report/complaint and informs Group Management within five (5) days, where the matter is deemed serious at the discretion of the Officer.

(c) Investigates the report/complaint within a reasonable period not exceeding thirty (30) days, in cooperation with Group Management, and jointly formulates proposals for resolving the issue. Any delay must be adequately justified.

(d) Keeps records regarding the results of investigations carried out in relation to submitted reports/complaints.

Group Management:
(i) ensures that employees are informed about this Policy,
(ii) supervises the proper implementation of this Policy, and
(iii) prepares and proposes revisions of the Policy in cooperation with the Reports Receipt and Monitoring Officer.

Under the responsibility of Group Management, the Whistleblowing and Complaints Management Policy is posted in updated form on the Group’s website www.lifecheck.gr.

8. Record Keeping and Data Analysis

The Group maintains a secure electronic archive containing all reports/complaints and related documents for at least five (5) years.
Group Management carries out systematic analysis of the data in order to address recurring or systemic issues and to implement corrective measures where required.

9. Personal Data

The processing of personal data within the framework of this Policy is carried out in accordance with applicable national and European legislation.
The data of all persons involved are retained for the purpose of verifying the validity of each report/complaint and investigating the respective incident.

If the persons involved in a report/complaint are not immediately informed of its content, in order to avoid potential interference with the investigation process, the reasons for such delay must be documented in writing and included in the case file.

Access to report/complaint data is granted only to those involved in the handling and investigation of the relevant incident. Access may also be granted to the persons referred to in the complaints, witnesses, and any other person with a legitimate interest.
The scope of access is determined on a case-by-case basis by the Group’s Reports Receipt and Monitoring Officer, depending on the status of the person and the seriousness of the case.
The identity of the reporting person and witnesses remains confidential, unless explicit consent is provided or it is proven that the report was made maliciously.

The Group adopts all necessary technical and organizational measures to ensure the protection of personal data.