Whistleblower Protection & Reporting

Purpose and legal framework

DIGITAL INFINITY DOO prohibits retaliation against people who make protected disclosures or assist in protected reporting. This public policy describes the main principles of Serbia’s Law on Protection of Whistleblowers (Official Gazette of the Republic of Serbia, No. 128/2014). It does not replace the employer’s applicable internal reporting act, designation of an authorised person or any mandatory procedure.

Protection can extend to people connected with employment, recruitment, business cooperation and other relationships covered by the law. Whether a particular disclosure qualifies is determined by the statutory conditions, not by the label placed on the report.

What may be reported

Protected disclosures can concern violations of regulations or human rights, misuse of public authority, danger to life, public health, safety or the environment, and prevention of large-scale damage, within the law’s scope. A report should describe the facts and available evidence as accurately as possible. Deliberately providing information known to be false or seeking an unlawful benefit is not protected abuse of the process.

You do not need to investigate the matter yourself or obtain information unlawfully. Ordinary employment or service questions can use the normal contact route; that does not prevent a qualifying matter from being raised as a protected disclosure.

Conditions for statutory protection

The company’s written whistleblower notice explains the statutory conditions for protection: disclosure through a route provided by law; reporting within one year of learning of the relevant conduct and no later than ten years after it occurred; and information that a person with comparable knowledge and experience would reasonably believe to be true on the available facts. Individual circumstances and the current law determine whether these conditions are met.

Protection can also apply where someone is wrongly believed to be a whistleblower or an associated person and suffers harmful action as a result. A report does not need to be proven correct before it can qualify for protection; knowingly false information and demands for an unlawful benefit are distinct from a concern raised on a reasonable factual basis.

Internal reporting and authorised person

The authorised person for receiving whistleblower reports at DIGITAL INFINITY DOO is Goran Krgović. Submit a written report to legal@digitalinfinity.rs, with the subject “Confidential — whistleblower report”, or send a sealed letter to Somborska 15, 21000 Novi Sad, Serbia, marked “Confidential — for Goran Krgović, authorised whistleblower officer”.

You may also contact Goran Krgović through legal@digitalinfinity.rs to arrange oral reporting and obtain the current internal reporting act. Share the facts relevant to the concern and available evidence, and indicate how you wish to be contacted. Use the designated legal channel rather than the general business enquiry form. Access to reports must be restricted to authorised handling; ordinary email cannot guarantee absolute technical security.

The applicable internal process must allow written and oral reporting, protect the identity of the whistleblower and act on disclosures without delay and no later than 15 days after receipt. The whistleblower is informed of the outcome within 15 days after the procedure concludes, in accordance with the law. On request, the whistleblower is entitled to information about progress and actions taken, access to the case file and attendance at procedural actions, in accordance with the law.

Confidentiality and handling

Identity and information that could reveal it must be protected and disclosed only where lawfully permitted or required, with the statutory safeguards. Information about another person named in a report must also be protected. Access to reports should be restricted to authorised handling and necessary action, with secure storage and appropriate recordkeeping.

The employer must act on anonymous reports within its authority and must not take steps to discover the identity of an anonymous whistleblower. A report may include a signature and contact details, but these are not a prerequisite for considering an anonymous disclosure. Absolute anonymity cannot be promised where the facts themselves identify someone or a lawful authority requires disclosure under the statutory safeguards.

The person receiving a report must explain when disclosure of identity to a competent authority may be necessary and inform the whistleblower before a necessary disclosure. Identifying information must not be disclosed to the person implicated in the report unless a specific law provides otherwise.

External reporting and public disclosure

You may make an external disclosure to the competent authority in the circumstances and manner provided by law. The competent authority depends on the subject, for example the relevant inspection, prosecutor or other body authorised to act. Internal reporting is not stated here as a universal prerequisite to statutory protection.

Public disclosure has separate statutory conditions, including specified urgent risks and risks to evidence. Publicly posting an allegation is not automatically protected merely because it concerns the company. Seek independent advice where needed; this policy does not restrict a lawful disclosure to authorities.

Information classified as secret

Information legally classified as secret follows a separate statutory reporting route. The company notice explains that such a disclosure is generally made first to the employer; if it concerns the designated recipient it is addressed to the head of the employer, and if it concerns the head of the employer it is addressed to the competent authority. The law also regulates escalation where the employer has not acted within 15 days.

Do not assume the general email channel or public disclosure is suitable for classified information. Obtain appropriate secure reporting instructions and follow the applicable secrecy safeguards. Public disclosure of classified information is not permitted unless the law provides otherwise.

Protection from retaliation and remedies

Retaliation, threats and harmful action connected with protected reporting are prohibited, including adverse treatment in hiring, employment, pay, training, progression or termination. Concerns about retaliation should be raised promptly through the authorised process or an appropriate external route, without losing the right to seek court protection.

The company notice explains that court protection is sought within six months of learning of the harmful action and no later than three years after the action occurred. The competent Higher Court is determined under the law by the place of the harmful action or the claimant’s residence. Damages and interim protection may be available under the applicable rules. Seek advice promptly; waiting for an internal response must not be assumed to suspend a legal deadline. This policy does not waive any statutory remedy.

Legal sources & related notices

References identify the relevant framework. Consult the current official texts and amendments for the activity concerned.

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