Whistleblowing Policy

INTERNAL WHISTLEBLOWING SYSTEM ACCORDING TO THE WHISTLEBLOWER PROTECTION LAW

OTHER REPORTS, COMPLAINTS, INITIATIVES

I. The employer has implemented an internal whistleblowing system according to Act No. 171/2023 Coll., on the protection of whistleblowers.

Reports under the whistleblower protection law are submitted in cases where the whistleblower intends to provide, and provides, information about possible unlawful conduct that has occurred or may occur concerning a person for whom the whistleblower, directly or indirectly, performed or performs work or similar activity, or concerning a person with whom the whistleblower has been or is in contact in connection with the performance of work or other similar activity, and which

  • has characteristics of a criminal offense,
  • has characteristics of an offense for which the law stipulates a fine, the upper limit of which is at least CZK 100,000,
  • violates the whistleblower protection law, or
  • violates other legal regulations or European Union regulations in the areas of
    • financial services, mandatory audit, and other verification services,
    • financial products and financial markets,
    • corporate income tax,
    • prevention of money laundering and terrorist financing,
    • consumer protection,
    • compliance with product requirements, including safety,
    • transportation safety, transport, and operation on roads,
    • environmental protection,
    • food and feed safety, and protection of animals and their health,
    • radiation protection and nuclear safety,
    • economic competition, public auctions, and public procurement,
    • internal order and security, life, and health,
    • personal data protection, privacy, and the security of electronic communication networks and information systems,
    • protection of the financial interests of the European Union, or
    • functioning of the internal market, including competition protection and state aid according to EU law.

Unless made anonymously, a report contains data such as the name, surname, and date of birth, or other information from which the whistleblower's identity can be deduced; it is presumed that the identity information of the whistleblower is truthful. A report may not contain information according to the first sentence if it was submitted by a person whose identity is known to the relevant person designated by the employer. For the purposes of the whistleblower protection law, "Work or other similar activity" is defined in §2, paragraphs 3 and 4 of the whistleblower protection law.

II. The whistleblower has the option to submit a report through the internal reporting system in writing or orally, or in person upon request. A sound recording or record that accurately captures the essence of the oral report is made for oral reports. A sound recording of an oral report can only be made with the whistleblower's consent. The relevant person allows the whistleblower to express their views on the recording or transcript, if made.

III. According to §9, para. 1 of the Whistleblower Protection Act, the employer has designated the relevant person. The identity of the relevant person and its contact details are provided in point V.

The whistleblower has the option to submit a report through the internal reporting system on the employer's website under the link "Complaints? Let us know." where this directive is also published.

The relevant person

  • receives and assesses the justification of reports submitted through the internal reporting system,
  • proposes measures to the employer as the obligated party to remedy or prevent illegal conditions based on the submitted report, unless this procedure could reveal the whistleblower's identity,
  • complies with the instructions of the employer as the obligated party, unless they jeopardize or hinder the performance of their duties under the Whistleblower Protection Act,
  • acts impartially in the performance of their duties under the Whistleblower Protection Act,
  • maintains confidentiality about facts learned during the performance of their duties under the Whistleblower Protection Act, even after the completion of this activity, unless the law provides otherwise.

The relevant person may not be penalized for the proper performance of their duties under the Whistleblower Protection Act.

IV. In the case of submitting a report, the relevant person proceeds according to §12 of the Whistleblower Protection Act.

The relevant person is obliged to inform the whistleblower in writing about the acceptance of the report within 7 days from the date of its receipt unless the whistleblower explicitly requested not to be informed about the acceptance, or unless it is clear that notifying the whistleblower about the acceptance would reveal the whistleblower's identity to another person. Within the same period, the relevant person informs the director of the organization about the anonymized wording of the report.

According to §20 of the Whistleblower Protection Act, the relevant person may not disclose to anyone the whistleblower's identity or information that could thwart or endanger the purpose of making the report.

The relevant person assesses the justification of the report impartially in accordance with the Whistleblower Protection Act, simultaneously assuming compliance with all conditions set by the Whistleblower Protection Act while following the instructions of the employer (organization) as the obligated party.

The relevant person is obliged to assess the justification of the report and inform the whistleblower in writing about the results of the assessment within 30 days from the date of receiving the report. In cases that are factually or legally complex, this period can be extended by up to 30 days, but not more than twice.

If the relevant person finds during the assessment of the report's justification that it does not qualify as a report under the Whistleblower Protection Act, they promptly inform the whistleblower in writing.

If the report is evaluated as justified, the relevant person proposes measures to the employer as the obligated party to prevent or remedy the illegal condition. The employer promptly informs the relevant person about the measures taken, who then informs the whistleblower in writing without unnecessary delay.

If the report is not evaluated as justified, the relevant person informs the whistleblower in writing without unnecessary delay that, based on the facts stated in the report and the circumstances known to them, they did not find suspicion of illegal conduct, or they found that the report is based on false information, and advises the whistleblower of their right to file a report with a public authority.

The relevant person is obliged to electronically maintain a record of data on received reports according to §21 of the Whistleblower Protection Act.

V. The person designated according to Act No. 171/2023 Coll., on the protection of whistleblowers:

Mgr. Martin Schmied
Quality Manager
Tel. +420 774 615 046
Email: martin.schmied@chropynska.cz

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