Internal notification system

For whom the Internal Notification System is intended

This internal reporting system is intended for employees of SULKO and SUNWIN (hereinafter referred to as the “Companies”), as well as to persons who have carried out or are engaged in voluntary activities, professional practice or traineeships (hereinafter referred to as “other similar activities”) and who have become aware of the infringement in connection with the performance of their work or other similar activity for the companies.

Work or other similar activity shall also mean applying for a job or other similar activity.

SULKO and SUNWIN point out that within the framework of the internal notification system they exclude the receipt of notifications from persons who do not perform work or other similar activities for the companies in accordance with Section 2 (3) (a), (b), (h) or (i) of the Law on Protection of Whistleblowers, i.e. from persons who do not perform work for the company in the basic employment relationship, service, volunteer activity, professional practice or an internship.

What can be reported through the Internal Notification System

According to the Whistleblower Protection Act a notification may be submitted containing information on possible infringements; which has occurred or is to occur in the companies, or with any other person with whom the notifier has been or is in contact with in connection with the performance of work or other similar activities in the companies and which

• has signs of any crime;
• has signs of an offense for which the law establishes the rate of a fine, the upper limit of which is at least CZK 100,000;
• violates the Whistleblower Protection Act, or
• infringes another law or regulation of the European Union in the field of:

1. financial services, statutory audit and other verification services, financial products and financial markets;
2. corporate income taxes,
3. preventing the legalisation of proceeds of crime and terrorist financing;
4. consumer protection,
5. compliance with product requirements, including their safety,
6. safety of transport, transport and road traffic,
7. environmental protection,
8. the safety of food and feed and the protection of animals and their health,
9. Radiation protection and nuclear safety,
10. competition, public auctions and public procurement,
11. protection of internal order and safety, life and health,
12. protection of personal data, privacy and security of electronic communications networks and information systems;
13. the protection of the financial interests of the European Union, or
14. the functioning of the internal market, including the protection of competition and state aid under European Union law.

Violations which violate a European Union law or regulation in one of the areas listed above can therefore be reported regardless of their degree of social harm (they may therefore be criminal offences, offences or other unlawful acts).

How can a notification be filed

• put in clipboardwhich is marked “NOTIFICATION ACCORDING TO THE LAW ON PROTECTION OF WHISTLEBLOWERS” and is located in the lobby of the reception hall of the SULKO complex, Czechoslovak Army 981/41, 789 01 Zářeh;
• through the postal service operator to the address: SULKO, Czechoslovak Army 981/41, 789 01 Zářeh, stating that the envelope containing the notice will be marked with the words: “NOTIFICATION UNDER THE LAW ON PROTECTION OF WHISTLEBLOWERS — DO NOT OPEN
• send via electronic mail to sulko@emkelty.cz;
• by word of mouth, by telephone callby calling the following telephone line: 736 538 130 or, at the request of the notifier, through an in-person meeting no later than 14 days from the date on which the notifier requested it. The request for a personal meeting must be sent to the above e-mail address sulko@emkelty.cz. If the deadline cannot be complied with for reasons on the part of the notifier, the competent person shall record this fact in the file.

The notification must contain details of the name, surname and date of birth, or other data from which the identity of the notifier can be inferred. Anonymously filed notices are not covered by the Whistleblower Protection Act.

In order to investigate the notifications filed under the Whistleblowers Protection Act, the following have been determined competent person: Ing. Martin Keltoš.

The notifier should, in view of the circumstances and information available to him at the time of the notification, have sufficient grounds to believe that the facts reported by him are true. Knowingly false notification may be sanctioned.

Whistleblowers shall not be subject to retaliatory measures in connection with the notification submitted.

Notifications can also be filed through an external notification system, which is run by the Department of Justice: https://oznamovatel.justice.cz/chci-podat-oznameni/

Handling notifications

• The competent person shall notify the notifier in writing without delay of receipt of the notification, but not later than within 7 days from the date of receipt of the notification. This shall not apply where it is clear that such a procedure would reveal the identity of the notifier or if the notifier so requested.
• The competent person shall assess the reasonableness of the information provided in the notification and shall inform the notifier in writing of the results of the assessment up to 30 days from the date of receipt of the notification. In cases of factual or legal complexity, this period may be extended by up to 30 days, but not more than twice. The person concerned shall inform the notifier in writing of the extension of the period and the reasons for its extension before its expiry.
• If the notification does not contain all the necessary information or data, the competent person shall invite the notifier to supplement it.

Record and storage of notifications

The competent person shall keep an electronic record of the notifications received, to the extent that:

• the date of receipt of the notification,
• the name, surname, date of birth and contact address of the notifier, or any other information from which the identity of the notifier can be inferred;
• a summary of the content of the notification and identification of the person concerned,
• the date of completion of the assessment of the reasonableness of the notification by the competent person and its outcome,
• preventive or corrective measures proposed and taken.

The competent person shall retain the notification and the documents relating to the notification for a period of 5 years from the date of receipt of the notification.

Only the relevant person has access to the records.