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Whistleblowing policy HAST GROUP

INFORMATION ON THE INTERNAL REPORTING SYSTEM

We, the company HAST GROUP s.r.o., with registered office at Koptovo 503, 739 34 Vaclavovice, ID 27835731, registered in the Commercial Register maintained by the Regional Court in Ostrava, Section C, Insert 30953, inform you about the following:

WHISTLEBLOWING POLICY HAST GROUP s.r.o.

I.   SETTING UP AN INTERNAL NOTIFICATION SYSTEM

Our company has established an internal whistleblowing system (the “Internal Whistleblowing System”) to notify us of possible infringements in the areas defined by Act No. 171/2023 Coll., on the protection of whistleblowers, or Directive (EU) 2019/1937 of the European Parliament and of the Council of 23rd October 2019 on the protection of persons who report infringements of Union law under point II. (“Notification”) by the physical persons listed in point III.

 

II.   EXCLUDED AREAS OF LAW FOR NOTIFICATION

Our Internal Whistleblowing System is designed for reporting violations:

  • having the characteristics of a criminal offense
  • having the characteristics of an offense for which the law provides for a fine of CZK 100,000 or more
  • 171/2023 Coll., on the protection of whistleblowers
    • violating any other law or regulation of the European Union falling under any of the following areas:
    • on financial services, due diligence, and other assurance services, financial products and financial markets,
    • on corporate income tax,
    • on the prevention of money laundering and terrorist financing,
    • on consumer protection,
    • on compliance with product requirements, including product safety,
    • on transport, traffic and road safety,
    • on environmental protection,
    • on food and feed safety and animal health,
    • on radiation protection and nuclear safety,
    • on competition, public auctions and public procurement,
    • on the protection of internal order and security, life and health,
    • on the protection of personal data, privacy and security of electronic communications networks and information systems,
    • on the protection of the European Union’s financial interests,
    • on the functioning of the internal market, including the protection of competition and state aid under EU law.

III.  WHISTLEBLOWER

A whistleblower who may use our Internal Notification System to submit a Notification is an individual who, in particular:

  • in employment, work experience or an internship
  • serves on the board of directors of our company
  • provides services for our company
  • performs activities under the supervision or direction of our contractors and suppliers and their subcontractors

and which has obtained information about our possible infringement under point II. in connection with their work or the performance of similar activities.

Work or similar activity also means applying for any of the above activities.

We do not exclude anyone who performs work or similar activities for us from making a Notification.

 

IV.   HOW TO SUBMIT A NOTIFICATION

Notification via our Internal Notification System can be made to the relevant person, the Marketing Manager:

  • by email, which should be sent to the email address oznameni@hastgroup.cz, which we have set up exclusively to receive Notices;
  • by telephone via telephone line +420 774 129 924; we also request that this method of submitting the Notification be used during usual working hours;
  • in writing by mail sent to the address of the company Novoveská 2064/5e, Ostrava-Mariánské Hory, 709 00 directly to the hands of the Marketing Manager;

At the same time, in the interest of maintaining confidence, we request that this mail be addressed directly to the Marketing Manager and that the mail be marked “WHISTLEBLOWING”.

For these purposes, prefer to send the mail ordinarily so that the sender is not obvious from the mail. You will be notified that the Notice has been received by us using the contact details contained in the Notice.

  • in person at the building located at Novoveská 2064/5e, 709 00 Ostrava we also request that this method of submitting the Notification be used during normal business hours and, if possible, after prior arrangement by e-mail under point 1. or by telephone under point 2.
  • via an anonymous box located in the dining room of the property at Novoveská 2064/5e, 709 00 Ostrava

 

Please ensure that the Notice contains the following information: your name, surname and date of birth or other information from which your identity can be inferred. To inform you of the receipt and the processing of your Notice, please also include your contact details. Only the person bound by confidentiality will be informed of your identity. However, without proper identification, the Notification may not be properly investigated and corrective action may not be taken.

Only Authorised Persons will be privy to all Notifications made and the identity of the Notifier.

 

V.   WHISTLEBLOWER PROTECTION

We will ensure that the Notification has been made through our Internal Notification System,

  • protecting the identity of the Whistleblower

protection against possible retaliation against the Whistleblower and other persons entitled to such protection under the law (such as relatives, close persons, etc.).

 

VI.   NOTICE

We assess the reasonableness and truthfulness of each Notification. If the Notice is reasonable and true, we will take corrective action.

We will defend ourselves if the Whistleblower knowingly provides false information in the Notice and/or does so in the interest of harming our business.

The making of the notification is not a breach of bank secrecy, contractual confidentiality and confidentiality obligations under the Tax Code or other types of confidentiality except for:

  1. ensure the protection of classified information and information the disclosure of which could obviously endanger ongoing criminal proceedings or the protection of special information pursuant to the law governing crisis management,
  2. maintain confidentiality in the performance of these activities:
  3. a) notary, notary candidate and notary trainee,
  4. b) a public prosecutor, an assistant public prosecutor and a legal assistant,
  5. c) attorney and law clerk,
  6. d) bailiff, bailiff candidate and bailiff trainee,
  7. e) judge, Constitutional Court judge, assistant judge and judicial candidate,
  8. f) an employee of a notary, a bailiff, an advocate and an employee of a company through which the advocate practises law as a partner under the law regulating the practice of law, or a similar foreign company, or another person who participates in the provision of legal services within such a company,
  9. maintain confidentiality when providing legal aid in proceedings before a court or other public authority; or
  10. maintain confidentiality in the provision of health services.

 

VII. INFORMATION ON HOW TO REPORT TO THE MINISTRY OF JUSTICE

Whistleblowers may further submit the Notification orally or in writing to the Ministry of Justice. You may use the website https://oznamovatel.justice.cz/chci-podat-oznameni/ to submit a written notification to the Department of Justice.

 

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