WHISTLEBLOWING - SYSTEMS FOR REPORTING POSSIBLE WRONGDOING
The company HBTX Interactive s.r.o., ID No.: 17825741 (hereinafter referred to as "the Company") in accordance with § 9 of Act No. 171/2023 Coll, on the protection of whistleblowers (hereinafter referred to as the "Whistleblower Protection Act") and related legal regulations, publishes information on how employees of the Company and other authorized persons listed below (hereinafter referred to as the "Whistleblower") may submit a report of a possible violation that has occurred or is about to occur in the Company, or with a third party with whom the Whistleblower has been or is in contact in connection with the performance of work or other similar activity for the Company, through the Company's internal reporting system and the external reporting system operated by the Ministry of Justice and the Financial Analytical Office.
WHICH INFRINGEMENTS CAN BE REPORTED
According to the Whistleblower Protection Act, it is possible to notify the Company or the competent state authority of a violation that:
a) has the characteristics of a criminal offence;
b) has the characteristics of a misdemeanour for which the law provides for a fine with an upper limit of at least CZK 100,000,
c) violates the Whistleblower Protection Act;
d) violates another legal regulation or regulation of the European Union in the field of:
- financial services, statutory audit and other assurance services, financial products, and financial markets,
- corporate income tax,
- the prevention of money laundering and terrorist financing,
- consumer protection,
- compliance with product requirements, including product safety,
- traffic safety, transport safety and road safety,
- protection of the environment,
- food and feed safety, protection of animals and their health,
- radiation protection and nuclear safety,
- economic competition, public auctions, and public procurement,
- protection of internal order and security, life, and health,
- protection of personal data, privacy and security of electronic communications networks and information systems,
- the protection of the financial interests of the European Union, or
- the functioning of the internal market, including the protection of competition and State aid under European Union law.
WHO IS ENTITLED TO SUBMIT THE NOTIFICATION (THE WHISTLEBLOWER)
According to the Whistleblower Protection Act the notification can be submitted by:
- the managing director and a member of the supervisory board,
- a shareholder of the Company,
- an employee of the Company performing work on the basis of an employment contract, an agreement to complete a job or an agreement to perform work,
- a tied agent of the Company (if a natural person),
- an employee or a member of the statutory body of the Company’s tied agent,
- a third party to whom certain activities of the Company have been delegated (if he is a natural person), or an employee or other representative of a third party to whom certain activities of the Company have been delegated, or a third party or an employee of a third party who provides supplies, services, construction work or other similar performance to the Company under a contract (contractor),
- a person undertaking voluntary work, work experience or an internship with the Company,
- an applicant or prospective applicant for an activity referred to in (a) to (g).
HOW TO SUBMIT THE NOTIFICATION
The Whistleblower may submit the notification through the Company's internal notification system in writing or orally to the so-called Competent Person: Dmitrijs Medvedevs (the "Competent Person")
Notification can be made in the following ways:
By email to: [email protected]
In paper form or in person at the Company's registered office: Olšanská 54/3, 130 00 Praha 3
At the request of the Notifier, the Competent Person shall receive the notification in person within a reasonable period of time, but no later than 14 days from the date of the Whistleblower's request.
EXTERNAL NOTIFICATION SYSTEM
Ministry of Justice
Notification of a possible violation under the Whistleblower Protection Act can also be made through the external notification system operated by the Ministry of Justice, which is available on the website https://oznamovatel.justice.cz/chci-podat-oznameni/
Financial Analytical Office (hereinafter referred to as the „FAO“)
In the event of an offence consisting in a violation of Act No. 253/2008 Coll., on Selected Measures against Legitimisation of Proceeds of Crime and Financing of Terrorism, as amended (hereinafter referred to as the "AML Act"), the notification shall be made via the external notification system operated by the FAO. Contact details for submitting a notification are available on the FAO's website https://fau.gov.cz/kontakty.
Notifications of AML Act violations cannot be submitted through the notification system to the Ministry of Justice and are received exclusively by the FAU.
OTHER INFORMATION
More detailed information on the method of submitting and handling notifications of possible infringements under the Whistleblower Protection Act through the Company's internal notification system, protection, rights and obligations of the notifier and other persons are contained in the Company's internal regulation "WHISTLEBLOWING - SYSTEMS FOR NOTIFICATION OF POSSIBLE ILLEGAL ACTIVITIES", or questions can be addressed to the Ministry of Justice, which provides methodological, advisory and other professional assistance in the field of the Whistleblower Protection Act: https://oznamovatel.justice.cz/.
