SATUM CZECH s.r.o. (hereinafter referred to as “SATUM”) consistently ensures compliance with all legal regulations and ethical principles. In order to fulfil the aforementioned, SATUM has implemented a mechanism enabling the reporting of breaches or imminent breaches of Act No. 170/2018 Coll., on Insurance and Reinsurance Distribution, other legal regulations to the extent to which they relate to the distribution of insurance or reinsurance, and directly applicable regulations of the European Union in the field of insurance distribution, through a special, independent and autonomous communication channel.
The reporting mechanism for breaches or imminent breaches of the Insurance and Reinsurance Distribution Act and other legal regulations on insurance distribution (hereinafter also referred to as “report” or “notification”) is an instrument for the prevention and detection of unlawful or unethical conduct in insurance distribution with the aim of contributing to the timely detection of such conduct and preventing its systematic repetition and negative consequences.
The whistleblower may be anyone, i.e., current or former clients (in any capacity, e.g., policyholder, entitled person, etc.), SATUM employees, business partners or other persons who become aware of facts which may lead, lead or have led to breaches of legal regulations related to SATUM’s business activities, or who become aware of other unethical or unfair conduct by SATUM.
Reports of the above-mentioned unethical or unlawful conduct should be clear, comprehensible, legible and must always contain identification of the breach to which it relates (as detailed as possible), including a description of the facts in which the whistleblower perceives a breach of Act No. 170/2018 Coll., on Insurance and Reinsurance Distribution. The notification may contain identification of the person who is allegedly responsible for the breach or imminent breach, and their relationship to SATUM. Reports may be submitted by the procedure set out below to the designated person responsible for receiving reports.
The designated person responsible for receiving reports is the compliance manager of SATUM.
Reports may be submitted anonymously; however, if the whistleblower requests information on the further procedure of SATUM, it is necessary to provide the whistleblower’s contact details in order to submit a response.
SATUM guarantees whistleblower protection and ensures that the identity of the whistleblower remains confidential. Data concerning the whistleblower may be disclosed only with their express consent or if required by legal regulations or subsequent court proceedings.
SATUM also excludes any negative impacts or sanctions, discrimination, unfair treatment towards the whistleblower or other adverse measures and guarantees the whistleblower protection against retaliation on account of a notification made in good faith.
If the report was not submitted anonymously, the compliance manager shall confirm all notifications received, if so requested by the whistleblower, and shall further proceed in such a manner as to ensure its objective and proper investigation. Notifications are dealt with without undue delay, taking into account the nature and gravity of the notification. If the whistleblower requests information on the results of the investigation, feedback is provided to their contact address, within a period appropriate for evaluating its content and adopting appropriate measures, only, however, if this procedure does not jeopardise the interest in protecting the identity of the whistleblower or the reported person, nor jeopardise the protection of their personal data or those of the reported person. All reports shall be evaluated by the designated person of SATUM, i.e., the compliance manager, in accordance with the applicable legal order and, depending on the content of the notification, appropriate internal or legal steps shall be taken. Following careful evaluation of the report, the compliance manager shall discuss it in a completely anonymous manner with the company management or, where appropriate, shall report the notified breach or imminent breach of the law to the relevant supervisory authorities of the Czech National Bank. The maximum time limit for resolving a notification is not specified.
Reports may be submitted:
through a written submission sent to the address of SATUM, i.e.:
In the subject line of the written submission or e-mail, state the word whistleblowing.
SATUM ensures protection of the personal data provided in accordance with applicable legal regulations and its internal regulations, in particular the Personal Data Protection Policy for Employees stored at S:\ISO\1_příručka kvality, řády and the Personal Data Processing Policy stored on the company’s website.
