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Reporting of Potential Unlawful Conduct

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

has established an internal reporting system within the meaning of Section 8 of the Act,

within the framework of which it accepts reports containing information about possible unlawful conduct which has occurred or is to occur at the company SATUM, for which the whistleblower, albeit indirectly, performed or performs work or other similar activity, or is in contact with it in connection with the performance of work or other similar activity, and which:

  1. has the characteristics of a criminal offence;
  2. has the characteristics of an administrative offence for which the law stipulates a penalty rate whose upper limit amounts to at least CZK 100,000;
  3. violates this Act;

or

  1. violates another legal regulation or regulation of the European Union in the area of:
    1. financial services, mandatory audit and other verification services, financial products and financial markets;
    2. corporate income tax;
    3. prevention of money laundering and terrorist financing;
    4. consumer protection;
    5. compliance with requirements for products including their safety;
    6. transport safety, carriage and traffic on roads;
    7. environmental protection;
    8. food and feed safety and the protection of animals and their health;
    9. radiation protection and nuclear safety;
    10. economic competition, public auctions and public procurement;
    11. protection of internal order and security, life and health;
    12. protection of personal data, privacy and security of electronic communications networks and information systems;
    13. protection of the financial interests of the European Union;
    14. functioning of the internal market including the protection of economic competition and state aid under European Union law.

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

I. Information on methods of reporting

  1. Reports may be made through the SATUM internal reporting system in the following ways:
    • by electronic mail to the address whistleblowing@satum.cz (access to this e-mail inbox is held exclusively by the designated person within the meaning of the Act, see further Article II);
    • 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 attention of the designated person!” to ensure that only the designated person within the meaning of the Act becomes acquainted with its contents, see further Article II);
    • in person in an interview with the designated person within the meaning of the Act (see further Article II), whereby the interview shall take place without the presence of other persons; however, the designated person shall request the whistleblower’s consent to the recording of the interview.
  2. 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 designated person

SATUM has appointed a designated person to perform activities pursuant to Section 11 of the Act, that is, inter alia, to receive and assess the substantiation of reports submitted through the internal reporting system, who is:

JUDr. Radim Bartoň
Telephone number: +420 777 151 014
E-mail address: radim.barton@satum.cz

The appointed designated person is of good repute within the meaning of Section 10(2) of the Act and is professionally qualified for their activity with regard to their legal education and also to previous 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 designated person is obliged to proceed impartially in the performance of their activity pursuant to the Act and to maintain confidentiality about facts which they have learned in the performance of their activity pursuant to the Act, even after its termination.

III. Information on accepting reports from persons “outside” SATUM

SATUM does not exclude, that is, it also accepts reports from whistleblowers who do not perform work or other similar activity for SATUM pursuant to Section 2(3)(a), (b), (h) or (i) of the Act, whereby these activities are understood to mean:

  1. dependent work performed in a basic employment relationship,
  2. service,
  3. volunteer activity,
  4. professional practice or traineeship.
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