ASSIST spol. s r. o. (hereinafter referred to as the “Company” or “we”), as a mandatory entity in accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers (hereinafter referred to as the “Act”), has established an internal notification system through which whistleblowers can submit notifications of possible unlawful acts that they have learned about in connection with the performance of their work.

What is notification

Notification means an oral or written notification of a natural person, the content of which contains information about a possible infringement that has occurred or is to occur with the Company for which the notifier, albeit through an intermediary, has performed or performs work or other similar activity, and which:

• has the hallmarks of a crime,
• has signs of an offence for which the law establishes the rate of a fine, the upper limit of which is at least CZK 100,000,
• violates the Act or violates any other law or regulation of the European Union in the areas defined in section 2 (1) (d) of the Act.

How can a notification be filed

Notifications can be made via our internal notification system to the relevant person. The competent person is the person designated by the Company to receive the notification, assess its reasonableness and propose measures to remedy or prevent the unlawful situation (in the case of the reason for the notification).

The person responsible for receiving and dealing with the notification is Mrs. Veronika Kadleckova. You may submit a notice in writing or orally in the following ways:

• in writing to the e-mail address: whistleblowing@assist.cz,
• by phone on the number +420 603 943 235, and on weekdays from 9:00 to 14:00,
• personally at your request
  • the date and place shall be determined by agreement with the person concerned by means of the e-mail or telephone number mentioned above. You will be allowed to submit a personal notice within a reasonable period of time after submitting your request (no later than 14 days).

In the event that you make a notice other than through the channels mentioned above (for example, you contact other employees of the Company), such notice will not be considered a notice within the meaning of the Act. The company can handle it in a different way and you are not protected under the law.

Who can file the notification

The notifier who can submit a notification through the internal notification system is any natural person who performs or has carried out work or other similar activities for the Company, i.e. current and former employees, job applicants, persons engaged in volunteer activities, professional practice or traineeships with the Company.

Company precludes receiving notifications from persons who do not perform work or other similar activities for it pursuant to Section 2 (3) (a), (b), (h) or (i) of the Act.

What should the notification contain

• name and surname, date of birth, or other data from which the identity of the notifier can be inferred,
  • this information may not include the notification if it has been submitted by a person whose identity is known to the person concerned;
• a description of the case with all relevant information,
• where possible, supporting documents substantiating those claims.

The company does not accept anonymous notifications.

How the notification is handled

After notifying you at the latest within 7 days of receipt of the notification the person concerned shall inform of receipt of the notification. You will not be notified only if you expressly request it in the notification, or it is clear that informing you of receipt of the notification would reveal your identity to a person other than the relevant persons without your consent.

Subsequently, within 30 days of receipt of the notification, the relevant person shall investigate the circumstances of the reported facts on the basis of the information provided by you in the notification. The relevant person will assess the reasonableness of your notification as part of the investigation.

Within the deadline 30 days from the date of receipt of the notification The relevant person shall inform you of the outcome of the reasonableness assessment, namely:

• extension of the time limit by another 30 days due to the complexity of the case (maximum possible extension of the deadline 2 times),
• the reasons for the notification and the proposed measures,
• the unreasonableness of the notification and the possibility to lodge a notification with a public authority; or
• the fact that this is not a notification under the Act.

Whistleblower protection

Receiving and processing notifications within the internal notification system is set up in such a way as not to reveal your identity. Only the Competent Person, who is bound by confidentiality and is obliged to maintain confidentiality of the content of the submission during the investigation of the complaint and after the termination of his/her employment, has the right to become aware of your identity and the content of the notification.

As whistleblowers, you are entitled to protection if you had legitimate grounds to believe that the information reported was true at the time of the notification. The Company will not take any negative (retaliatory) action against you in connection with the filing of the notification, such as termination of employment, reduction of wages, termination of permanent cooperation or transfer to another position, etc. These measures will not apply to so-called related persons (according to Section 4 (2) of the Act).

Legal notice on knowingly submitting a false report

Knowingly false notification is an offence under the Act, for which a fine of up to CZK 50,000 can be imposed. At the same time, such a whistleblower does not have protection from retaliatory measures under the Act.

External notification system

The notifier has the right to submit a notification complying with the requirements according to the Act also through the external notification system of the Ministry of Justice at: https://oznamovatel.justice.cz/chci-podat-oznameni/

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