Whistleblowing

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Whistleblowing

Protection of persons who report violation of the law (whistleblowing)

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 was adopted in order to protect whistleblowers who report illegal conduct that has the characteristics of a criminal offense or a misdemeanor and whistleblowers learned about it in connection with work or other similar activity. Its purpose is primarily to protect whistleblowers from retaliatory measures by the employer or colleagues. For this reason, when reporting through an internal channel, the identity of the reporting party will remain confidential, which will only be known to the relevant person, who is required to maintain confidentiality.

Who can report illegal conduct

Whistleblower can be a natural person in relation to KCZ (e.g. an employee, contractual partner, job applicant, employee of a service organization, etc.).

What can whistleblower report

Possible illegal act that bears the characteristics of a criminal offense or misdemeanor and the whistleblower learned about it in connection with work or another similar activity.

Areas of violation of the law

  • any unethical or illegal conduct;
  • contracting supply contracts and prevention of money laundering;
  • safety and product compliance with regulations;
  • safety at work;
  • environmental protection;
  • consumer protection;
  • protection of privacy and personal data and security of networks and information systems.

How to report / Receiving of report

You can submit a report through a special, independent and separate communication channel ensuring the confidentiality of the information provided, the protection of the whistleblower and his personal data, only regarding the above-mentioned areas. In case of report outside the mentioned areas, it is necessary to contact other competent public authorities or the court.

Whistleblower can choose a tool for reporting in written or verbal form and depending on the degree of anonymity he requires, from a personal meeting with authorized persons to a fully anonymous way through the Help-Link. Internal report system of KCZ includes the following tools for reporting objectionable behavior:

a) By phone at Help-Link, tel: 774770045. In this case, a qualified employee of the social agency that provides Help-Link will evaluate the complaint and discuss further steps with the whistleblower. If it follows from the interview that this is an initiative to be dealt within KCZ, this employee will forward adequate information to one of the authorized persons. If the whistleblower so wishes, feedback to the whistleblower will only be provided through a Help-Link employee, and the whistleblower will remain completely anonymous for KCZ. This report channel can only be used on Wednesdays from 10:00 a.m. to 2:00 p.m.

b) By email at Help-Link koito@socialniagentura.cz. Communication takes place in a similar way as during a telephone call, i.e. with feedback via the Help-Link. The employee of the social agency forwards the content of the email to authorized person of KCZ, but not the whistleblower’s contact. Email report can be submitted at any time. Operator of Help-Link is bound by confidentiality and transmits only the information that is necessary for the substance of the report and its resolution, and feedback is provided through the operator of Help-Link.

c) Oral notification to one of the authorized persons. The addressed authorized person will make a written record the interview or, with the whistleblower's permission, record the interview. The interview is considered as proof that the initiative has been received and therefore there is no need to submit further information on the receipt of the record and the initiation of the solution.

d) Email sent to email address oznameni@koito-czech.cz. All authorized persons have access to the e-mail box of this address and therefore it is sufficiently ensured that a timely response to reports takes place. Feedback will be provided to the sender's email or by any other means that the whistleblower indicates as possible in the email.

e) Email sent to authorized persons’s address. In this case, we recommend marking "message read confirmation" in your email. We also recommend choosing at least 2 addresses so that even in the absence of one authorized person timely responding is possible. As in the previous case, feedback will be provided to the sender's email or in another way that the whistleblower indicates as possible in the email.

f) In paper form directly to the mailbox at the HR office or at one of the gatehouses, ideally in a sealed envelope with the name of one of the authorized persons. If report is dropped into a mailbox without an envelope and an addressee name, anonymity cannot be guaranteed, as the mail is collected from mailboxes by various members of the HR section.

g) By telephone to one of the authorized persons. Telephone interview is considered as a proof that the initiative has been received and there is no need to submit another report on the initiation of the solution. Authorized person will make a written record of the interview, which will include a contact to whom feedback will be given on the status of resolution of the initiative.

Report content

  • detailed description of the illegal act (the subject of report, where the whistleblower learned about it, evidence and supporting materials, etc.)

Protected report may also include:

  • identification of the whistleblower – name, surname, date of birth, address of permanent residence, contact address for notification.

Identity of the whistleblower is important when assessing the report, as there may be a need to contact the whistleblower with a request to clarify or add the information to the report. Contact details of the whistleblower are also required to notify of the receipt of the report and subsequently to notify of the result of the assessment of the report.

Deadlines

Whistleblower has the right to be notified of report’s acceptance within 7 days of submitting the report and to be notified of the outcome of the assessment within 3 months at the latest to the electronic or postal address provided by the whistleblower, unless he has waived this right in advance. The notification will not be sent in the case of an anonymous submission and if sending it could jeopardize the interest in protecting the identity of the informant and his personal data, or a third party.

GDPR

Personal data of the whistleblower are processed for the purposes of dealing with reports in accordance with Regulation (EU) No. 2016/679 of the European Parliament and of the Council, on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC, and related regulations.

Instruction

In the event of a knowingly false report, whistleblower may commit a misdemeanor or a criminal offense.