Whistle-blower line

Information for whistleblowers

In accordance with Section 21(6)(b) of Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing (“AML Act”), each obliged entity must establish an internal whistleblowing system within the meaning of Act No. 171/2023 Coll., on Whistleblower Protection (“Whistleblower Act”). The system includes the option for any employee (including persons who are not in a primary employment relationship with the Company) to submit a report of the conduct described below.

What conduct is to be reported?

Notification may be submitted for breaches of obligations under the AML Act and other notifications within the meaning of Section 2(1) of the Whistleblower Act, namely conduct that

• has characteristics of a criminal offence;
• has characteristics of a misdemeanour for which the legislation provides for a fine of at least CZK 100 000;
• Violates the Whistleblower Act;
• Violates legislation or regulations of the European Union in the area of financial services, statutory audit and other assurance services, financial products and financial markets;
• Violates legislation or regulations of the European Union in the area of corporate income tax, prevention of laundering of proceeds of crime and financing of terrorism, consumer protection, safety of transport, transportation and traffic on roads, environmental protection, food and feed safety and protection of animals and their health, radiation protection and nuclear safety, competition, public auctions and public procurement, protection of internal order and security, life and health;
• You witness and violates regulations under the AML Act.

You do not have to witness the commission of the acts listed above, it is sufficient if you suspect that such conduct is imminent and have reasonable grounds to suspect that the consequence may occur in the future.

It is important that you have reasonable grounds to believe that the facts reported or disclosed are authentic and true. The notification should also be based on credible facts and evidence.

If you were making a notification about facts that concern the security of the Czech Republic, we could not assess such a report under this Whistleblower Act as such information is excluded from the notification. A specific list of such excluded areas can be found in Section 3(3) of the Whistleblower Act (in particular, security issues, intelligence services, etc.). If you make a notification in these areas, not only are you not protected under the Whistleblower Act, but you may also be committing an offence or even a criminal offence.

You can also make any notification anonymously, and we guarantee that we will deal with the notification in the same way as we would a non-anonymous notification.

Who handles the notifications?

Your notification will be received by our notification investigator:

Lucie Šutovská
Tel. +420 724 193 075.

The Notification investigator is bound by confidentiality and will protect your identity and the information you have provided. If you make an anonymous notification, the notification investigator will not seek your identity.

How to make a notification?

You can file a notification by:

• The whistleblower line
• Orally via the notification investigator’s telephone number +420 724 193 075.
• In person orally at the Company’s registered office or at another location agreed with the notification investigator (you can decide using the contact details of the notification investigator above), whereby you will be given the opportunity to make a notification within a reasonable time after your request, but no later than 14 days.

If you make a notification by other means than through the channels set out above (for example, by email to another colleague at the Company), such notification will not be treated as a notification for the purposes of the Whistleblower Act. The Company may therefore deal with it in another way, and you will not be protected under the Whistleblower Protection Act.

External notification option

In addition to the internal notification system, the Whistleblower Protection Act also allows for other methods of notification. These external notification methods are:

• Notification through the Department of Justice’s notification system, available at: https://oznamovatel.justice.cz/.

As we are affected by the AML regulation, we also have specific rules where external notifications can be made. If the notification relates to one of our employees, management, etc. has violated AML, you cannot make an external notification through the notification system at the Ministry of Justice or publish such a notification. In that case, you must make the notification through:

• Financial Analytical Office
• Chamber of Tax Advisors of the Czech Republic;
• Chamber of Auditors of the Czech Republic

How is the notification handled?

We will confirm your notification in writing within seven calendar days, unless the notification was made anonymously (without knowing a specific address to which we can respond) or it is clear that notification of receipt of the notification would disclose your identity to another person.

Based on information from you, the investigator will assess the circumstances of the reported conduct at the Company. Investigator will then propose measures to prevent the reported conduct from continuing and to remedy the situation. Adoption and implementation of these measures shall also be monitored by the investigator. We can assure you that the Company will not take any retaliatory action against you in connection with your notification, such as termination of employment, reduction in pay or other disadvantage, termination of continuing cooperation, or reduction in compensation, for example.

The notification investigator will notify you how was the notification handled no later than 30 days after receipt of the notification. In complex cases, the time limit may be extended by up to 30 days, two times in a row. Once specific actions have been taken, your notification investigator will inform you without undue delay.

Important information before submission

You may only submit true and authentic notifications. You may not make knowingly false notifications. If you do, the law does not protect you and you may be subject to retaliation and consequences from the Company, the damaged person and government authorities.

You also cannot engage in conduct that would constitute a criminal offense (such as violating the confidentiality of correspondence or hacking into an information system) when making a notification.

Whistle-blower line

There are two options to choose from in protecting your identity:

We do encourage confidential disclosure as such disclosure will help the notification investigator to better investigate your report.

Anonymous: If you selected to be anonymous you don’t need to supply your name or any information that might reveal your identity. Nobody will ever know that you provided us with this information. Unfortunately, this means that we cannot contact you for more information if we need to.

Confidential: If you agree to the confidential disclosure of your personal details, then your name and contact details will be known to the person responsible for the investigation.