Information for whistleblowers

Information for whistleblowers 

pursuant to § 9(2)(b) of Act No 171/2023 Coll., on the protection of whistleblowers 

(https://www.e-sbirka.cz/sb/2023/171?zalozka=text) 

In accordance with Act No. 171/2023 Coll., on the protection of whistleblowers (hereinafter referred to as "the Act"), the Z+M GROUP companies have an internal whistleblowing system in place, which is intended only for persons who have become aware of a possible violation at the Companies in connection with the performance of work or other similar activities for the Companies. 

The receipt of reports from persons who do not perform work or other similar activities for the Companies pursuant to § 2(3)(a), (b), (h) or (i) of the Act through the Companies' internal reporting system is excluded. Such persons may submit notifications through the external notification system of the Ministry of Justice. 

Contact details of the Competent Person designated by companies to carry out activities under the Act: 

Telephone: +420 601 520 786 (the above telephone number is only accessible to the Competent Person). 

Secure email: oowb@zmgroup.cz 

Address for service of the Notice: Valchařská 3261/17, 702 00 Ostrava - Moravská Ostrava

Dedicated boxes marked 'Internal notification system - for the competent person': 1. Křivá 25, 702 00 Ostrava - Moravská Ostrava, 2. K Bílému Vrchu 2960/8, 193 00 Praha - Horní Počernice 

Methods of notification via the companies' internal notification system: 

In writing

  • Inbox
  • For the purposes of written notification under these internal regulations, two mailboxes are located at Křivá 25, 702 02 Ostrava - Moravská Ostrava and K Bílému Vrchu 2960/8, 193 00 Praha - Horní Počernice. Dedicated boxes marked 'Internal notification system - for the relevant person. The box is secured by a lock and access to it is restricted to the person concerned.
  • Letter
  • Written notification sent via the postal service provider shall be sent to the following address: Valchařská 3261/17, 702 00 Ostrava - Moravská Ostrava, and the whistleblower shall indicate on the envelope 'For the hands of the person concerned only'. Employees receiving mail from delivery agents must never open this envelope and it is their duty to ensure that it is handed over personally only to the person concerned; they must make a record of this handing over.
  • E-mail
  • Notifications may be sent electronically to the following e-mail address: oowb@zmgroup.cz Access to e-mail is restricted to the person concerned.

Verbally

  • Verbal submissions can be made by telephone. The whistleblower shall dial the telephone number +420 601 520 786. This is a direct telephone line exclusively to the person concerned. This line is not subject to reception or transfer by another person.
  • If the person concerned cannot answer the call, the whistleblower has the option of recording the notification as a voice message. In this case, the whistleblower agrees to the audio recording of his/her verbal notification.
  • If a call is made by the whistleblower to the person concerned, an audio recording or recording shall be made of the notification which faithfully captures the substance of the oral notification. The audio recording shall be made only with the consent of the whistleblower.
  • The whistleblower shall have the opportunity to comment on the recording or the transcript of the sound recording, if made. The whistleblower's statement shall be attached to the recording or transcript.

In person

  • A whistleblower who wishes to make a notification in person shall contact the appropriate person by one of the methods listed above and request to make the notification in person. For this purpose, the whistleblower must provide the contact details of the relevant person so that he or she can contact him or her and arrange a time for the notification to be made orally.
  • The competent person shall arrange a meeting with the whistleblower within a reasonable time of receipt of the request, but not later than 14 days, unless otherwise agreed.
  • The personal submission shall take place at the address of the company's registered office at Valchařská 3261/17, 702 00 Ostrava - Moravská Ostrava, unless the whistleblower and the competent person agree on another location.

 

External notification systém 

The whistleblower is not obliged to submit a notification through the employer's internal notification system, but has the right to do so at his/her own choice through an external notification system established and operated by the Ministry of Justice. 

Elements of notification 

Details of the whistleblower

  • The notification should include the name, surname and date of birth of the whistleblower or other information from which the identity of the whistleblower can be inferred.
  • The whistleblower shall also communicate/transmit to the competent person a contact address, which serves in particular to enable the competent person to inform him/her in writing about the notification received, the validity of the notification, the measures taken.
  • If the whistleblower does not provide contact details in order to enable the competent person to inform him in writing of the receipt of the notification, its validity and the measures taken, the whistleblower shall be deemed not to wish to be informed.

 

Facts to be notified

  • The whistleblower shall indicate in the notification the facts constituting the infringement. The success of the notification may be affected by the amount of information, data and clues provided by the whistleblower and the possibilities to verify them, so the whistleblower should take care to ensure that his notification is specific and clear.
  • In particular, the whistleblower shall describe the area to which the notification relates, when and how the conduct occurred or was intended to occur, how he/she became aware of it, whether and what evidence he/she has of the facts disclosed and, if possible, whether he/she has attached such evidence to the notification, whether he/she is aware of the persons or witnesses involved, etc.
  • A notification made by a whistleblower under these Internal Rules shall not constitute a breach of his contractual duty of confidentiality or his duty of confidentiality under the legislation governing his work or other similar activity.