WHISTLEBLOWING SYSTEM
The internal whistleblowing system is shared within SPOLCHEMIE group. You can raise the concerns or make a notification of any violation of the company’s Code of Conduct (https://www.spolchemie.cz/en/other/code-of-conduct/) by e-mail, by telephone between 7:30 a.m. and 3:30 p.m., by voicemail at the numbers listed above, or in person by appointment through any of the following persons:
Hana Zemanová | Vojtěch Hrdlička | Kamila Vítek Derynková |
e-mail: zemanova@cssas.cz | e-mail: hrdlicka@spolchemie.cz | e-mail: derynkova@spolchemie.cz |
tel.: +420 477 16 2521 mob.: +420 721 377 829 | tel.: +420 477 16 2066 mob.: +420 724 166 630 | mob.: +420 725 747 490 |
in the following ways:
by email, by phone between 7:30 a.m. and 3:30 p.m., via voicemail at the numbers listed above, or in person by prior appointment.
WHAT TO REPORT
The internal whistleblowing system accepts reports regarding any violation of the Company’s Code of Conduct (https://www.spolchemie.cz/eticky-kodex/) or any unlawful conduct that:
Constitutes a criminal offense;
Constitutes an administrative offense punishable by a statutory fine with an upper limit of at least CZK 100,000;
Violates the Whistleblower Protection Act; or
Violates another legal regulation or European Union regulation in the areas of:
financial services, statutory audit and other assurance services, financial products, and financial markets;
corporate income tax;
prevention of money laundering and terrorist financing;
consumer protection;
compliance with product requirements, including product safety;
transport safety, traffic safety, and road operations;
environmental protection;
food and feed safety, animal health, and animal welfare;
radiation protection and nuclear safety;
competition, public auctions, and public procurement;
protection of internal order and security, life, and health;
protection of personal data, privacy, and security of electronic communications networks and information systems;
protection of the financial interests of the European Union; or
functioning of the internal market, including the protection of competition and state aid under European Union law.
WHO CAN REPORT
Natural persons who have performed or are performing work or other similar activities in connection with which the report is made may submit reports through the internal whistleblowing system.
For the purposes of the Whistleblower Protection Act, work or other similar activity specifically means:
- dependent work performed within a primary employment relationship;
- independent gainful activity (self-employment);
- exercise of rights associated with participation in a legal entity;
- performance of functions as a member of an organ of a legal entity;
- fulfillment of tasks within the activities of a legal entity, in its interest, on its behalf, or on its account;
- administration of a trust fund;
- volunteer activity;
- professional practice or internship; or
- exercise of rights and obligations arising from a contract for the provision of supplies, services, construction works, or other similar performance.
Exclusion Clause: Obligated Entities exclude the receipt of reports from persons who do not perform work or other similar activities for the Obligated Entities pursuant to Section 2(3)(a), (b), (h), or (i) of the Whistleblower Protection Act.
ANONYMOUS REPORTS
Facts reported via an anonymous report, or a report that does not meet other requirements of the Whistleblower Protection Act, will be investigated in accordance with the applicable internal regulations adopted by the Obligated Entity.
PROTECTION OF IDENTITY AND PERSONAL DATA
The identity of the whistleblower shall always be protected to the maximum extent possible and shall be known only to the persons concerned. Obliged persons shall not obtain the identity of the whistleblower. Retaliatory measures against the whistleblower shall not be admissible regardless of the nature of the notification.
The personal data of the whistleblower to the extent mentioned above, together with any voice recording of the oral notification, may only be handled by the competent persons for the purpose of contacting the whistleblower, for the purpose of keeping records of notifications made and for the purpose of preserving the notification, all for a period of 5 years after the notification has been made. The company’s privacy policy is available at https://www.spolchemie.cz/gdpr_cs/.