Information for reporters of unlawful conduct

Reported through the internal reporting system of the company ROMODROM, IČ 265 37 036, registered office Rybná 716/24, Staré Město, 110 00 Prague 1, registered in the register of public benefit companies kept by the Municipal Court in Prague under file No. O 1447 (hereinafter also referred to as the company).

Introductory information

The public benefit company ROMODROM manages an internal reporting system and ensures the protection of reporters based on legal obligations imposed on the company as a so-called "mandatory subject" under Act No. 171/2023 Coll., on the protection of reporters (hereinafter also referred to as "ZOCH"). To fulfill the obligations under the Act on the Protection of Reporters, the company has issued a binding internal directive on the internal reporting system and the protection of reporters at the company ROMODROM (hereinafter also referred to as the "internal directive").

Through the company's internal reporting system, a qualified natural person (hereinafter also referred to as a "reporter") can submit a report of unlawful conduct, which the reporter learned about in connection with work or similar activity for the company (hereinafter also referred to as a "report").

What reports of unlawful conduct can be submitted?

Through the internal reporting system of the company, it is possible to submit notifications that: contain information about possible unlawful conduct that has occurred or is to occur at the company ROMODROM a. s., for which the notifier performed or performs work or other similar activity, or at a person with whom the notifier was or is in contact in connection with the performance of work or other similar activity (in a work context), and which:

1. have characteristics of a criminal offense,
2. have characteristics of an offense for which the law sets a fine rate, the upper limit of which is at least 100,000 CZK,
3. violate the law on the protection of whistleblowers or
4. violate another legal regulation of the Czech Republic or a regulation of the European Union in the field of:
   
   

• financial services, mandatory audit and other verification services, financial products and financial markets,
• corporate income tax,
• prevention of money laundering and terrorism financing,
• consumer protection,
• compliance with product requirements including their safety,
• transport safety, transportation and operation on roads,
• environmental protection,
• food and feed safety and animal protection and health,
• radiation protection and nuclear safety,
• economic competition, public auctions and public procurement,
• internal order and security, life and health protection,
• personal data protection, privacy and 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 the law of the European Union.

Who can submit a report on unlawful conduct

The notifier, who can submit a report through the internal reporting system at ROMODROM o.p.s., is any natural person who performs or has performed work or other similar activity for the company and submits the report in this work context as:

1. an employee who works for the company under an employment contract or based on an agreement on work activity or work performance agreement;
2. a former employee of the company;
3. a job applicant at the company;
4. a person who performs or has performed professional practice or internship at the company;
5. a person who is or has been a partner of the company;
6. a person who is a member of the statutory or other body of the company;
7. a person who either directly or indirectly performs or has performed external supplier activities for the company based on a contract for the provision of supplies, services, construction works, or other similar performance.

A natural person has the right to protection as a notifier under the Whistleblower Protection Act and internal guidelines if:

• the above conditions are met and at the same time
• this person has reasonable grounds to believe that the information provided to them was true at the time of reporting and that the report was necessary to uncover the aforementioned unlawful act.

The law on the protection of whistleblowers is not affected by this internal directive, nor is the legal obligation to report directly to the authorities responsible for criminal proceedings those criminal offenses that are exhaustively listed in Section 368 of the Criminal Code and fall under the so-called reporting obligation (e.g. murder, grievous bodily harm, etc.). Possible ways to report unlawful conduct: 1. In writing in electronic form to the email oznameni@romodrom.cz 2. In writing in paper form sent as a postal item to the postal address of the company ROMODROM, o.p.s., Na Březince 930/6, 150 00 Prague 5, with the envelope marked with the words: "Confidential, for the attention of the relevant person", or "DO NOT OPEN - for Šárka Vlková", or "Whistleblowing - DO NOT OPEN", or in a similar clear manner. 3. Orally - on the phone number +420 778 495 250 (Šárka Vlková) 4. In person by agreement with the relevant person; in this case, the relevant person must accept the report personally from the whistleblower within a reasonable period, but no later than fourteen (14) days from the day the whistleblower requested it. Repeated reports from the same whistleblower on the same matter are not permissible and will not be re-investigated, with the whistleblower being informed with a brief explanation. This does not apply if the subsequent report contains new information and facts compared to the previously submitted report. The person responsible for receiving and processing reports at the company ROMODROM o.p.s. is: Name: Šárka Vlková Email address: sarka.vlkova@romodrom.cz Phone: +420 778 495 250

Within the framework of receiving and assessing the justification of the notification, the relevant person always acts independently, impartially, and neutrally, with the right to request necessary information and documents from all organizational units and all employees of the company ROMODROM o.p.s., as well as other forms of cooperation.

The relevant person shall ensure that the addressed employees cannot become acquainted with the content of the notification and that no fact revealing the identity of the notifier shall be disclosed.

Deadlines for notifying the notifier and assessing the justification of the notificationThe relevant person shall send a notification of acceptance of the notice to the notifier no later than seven (7) days from the date of submission of the Notice.

This does not apply only in cases where:

1. The notifier expressly requests the relevant person not to inform him about the receipt of the notification, or
2. it is evident that by informing about the receipt of the notification, the identity of the notifier would be disclosed to another person.
   

The relevant person is obliged to assess the validity of the notification and inform the notifier in writing about the results of the assessment within thirty (30) days from the date of receipt of the notification.

In cases that are factually or legally complex, this period can be extended by an additional thirty (30) days, but no more than twice, i.e., the maximum duration for assessing the validity of the notification may in exceptional cases be ninety (90) days from the date of submission of the notification.

The relevant person shall always inform the notifier in writing about the extension of the deadline and the reasons for its extension before its expiration.

Prohibition of retaliatory measures against notifiers

Within the framework of the internal reporting system, as well as in related or other activities of all employees and/or members of the company's bodies, a strict prohibition on taking any retaliatory measures against notifiers applies. Retaliatory measures in this context mean actions or omissions related to the work or other similar activities of the notifier that were triggered by the submission of the notification and that may harm the notifier. Meeting these conditions, retaliatory measures include, for example, termination of employment, non-renewal of fixed-term employment, reduction of salary or bonus, denial of a personal supplement, transfer or reassignment to another job, prevention of professional development, termination or withdrawal from a (business) contract, or interference with the right to personal protection. 

The prohibition of retaliatory measures also applies to other protected persons mentioned in § 4 para. 2 of the Whistleblower Protection Act, in particular to a person who provided assistance in obtaining information that is the subject of the notification, to a person who is closely related to the notifier, or to a person who is an employee or colleague of the notifier. Additional channels and options for reporting unlawful conduct.

Notifications can also be submitted, if the legal conditions are met, through the external reporting system of the Ministry of Justice and/or directly to the relevant public authority, i.e.At the Police of the Czech Republic, the public prosecutor's office and/or the relevant authorities of public administration according to their jurisdiction (e.g. Czech Environmental Inspection, Office for Personal Data Protection, etc.). In this case, the notification is received, investigated, and assessed by the Ministry of Justice or another relevant public authority.

External channel for reporting illegal activities:

Ministry of Justice of the Czech Republic
Vyšehradská 424/16
128 10 Nové Město

Application: https://oznamovatel.justice.cz/chci-podat-oznameni/
Email: oznamovatel@msp.justice.cz or mnetocny@msp.justice.cz
Phone: +420 221 997 840