Reporting of Potential Unlawful Conduct

SATUM CZECH s.r.o. (hereinafter “SATUM”) in accordance with the Whistleblower Protection Act No. 171/2023 Coll. of 2 June 2023 (hereinafter the “Act”) and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report violation of Union law (hereinafter the “Directive”)

has established an Internal Reporting System pursuant to Section 8 of the Act

under which it receives Reports containing information about possible unlawful conduct that has occurred or is about to occur at SATUM, for which the whistleblower, albeit indirectly, performed or performs work or other similar activities, or is in contact with it in connection with the performance of work or other similar activities, and which

a) constitutes elements of a criminal offence,

b) constitutes elements of an administrative offense for which the law sets a fine with an upper limit of at least CZK 100,000,

c) violates this Act, or

d) violates other legal provisions or European Union provisions in the area 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 their safety;
transport safety and road traffic operations;
environmental protection;
food and feed safety and animal welfare and health;
radiation protection and nuclear safety;
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 the functioning of the internal market including protection of competition and state aid under European Union law.

SATUM hereby publishes the following information pursuant to Section 9(2)(b) of the Act:

I. INFORMATION ON REPORTING METHODS

A. Reports may be made through SATUM’s internal reporting system by the following methods:

by electronic mail to the address whistleblowing@satum.cz (access to this email account is held exclusively by the Responsible Person within the meaning of the Act, cf. section II. below);
in writing to the address SATUM CZECH s.r.o., 28. října 3346/91, 702 00 Ostrava (the envelope must be clearly marked with the text “DO NOT OPEN – Whistleblowing – exclusively for the responsible person!” to ensure that only the Responsible Person within the meaning of the Act becomes acquainted with its contents, cf. section II. below);
in person through an interview with the Responsible Person within the meaning of the Act (cf. section II. below, whereby the interview shall be conducted without witnesses, however the Responsible Person will request your consent to record the interview).

B. Reports may also be made to the Ministry of Justice of the Czech Republic, for example through the external reporting system available at the internet address https://oznamovatel.justice.cz/chci-podat-oznameni/.

II. INFORMATION ON THE RESPONSIBLE PERSON

SATUM has designated a Responsible Person to perform activities pursuant to Section 11 of the Act, i.e. inter alia to receive and assess the reasonableness of reports submitted through the internal reporting system, who is:

JUDr. Radim Bartoň

telephone number: +420 777151014

email address: radim.barton@satum.cz

The designated Responsible Person is of good character within the meaning of Section 10(2) of the Act and is professionally qualified for their activities in view of their legal education and former practice as an advocate, during which they represented clients – natural persons in disputes against employers, state authorities, or as injured parties in criminal proceedings. The Responsible Person is obliged to act impartially in the performance of their duties under the Act and to maintain confidentiality regarding facts which they became aware of in the performance of their duties under the Act, including after termination of their duties.

III. INFORMATION ON RECEIVING REPORTS FROM PERSONS OUTSIDE SATUM

SATUM does not exclude, i.e. also accepts Reports from whistleblowers who do not perform work or other similar activities for SATUM pursuant to Section 2(3)(a), (b), (h) or (i) of the Act, which is otherwise understood as

a) dependent work performed within a basic employment relationship,

b) service,

h) voluntary work,

i) professional practice, internship.