WHISTLEBLOWING – PROTECTION OF WHISTLEBLOWERS
STEINBAUER LECHNER s.r.o. (Ltd.), Company Identification No. 47239042 (hereinafter the “Company”), operates an internal reporting system in accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers, for reporting suspected unlawful conduct of which a whistleblower has become aware in connection with work or other similar activities.
1. Designated Person
Eva Prokešová
Telephone: +420 387 011 326
Email: eva.prokesova@steinbauer-lechner.cz
2. Reporting Channels
- In writing – using the secure reporting form: https://www.faceup.com/c/9eyw5xpv
- Orally – by recording a voice message through the same reporting system; alternatively, by telephone upon arrangement with the designated person.
- In person – by prior arrangement with the designated person at the Company’s registered office, normally during working hours from 7:00 a.m. to 3:30 p.m. At the whistleblower’s request, an in-person report will be accepted within a reasonable period, no later than 14 days after the request is made.
3. Persons Eligible to Submit Reports
In accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers, the Company excludes the acceptance of reports through its internal reporting system from persons who do not perform work or other similar activities for the Company as specified in Section 2(3)(a), (b), (h) or (i) of the aforementioned Act.
The internal reporting system is therefore intended primarily for persons performing dependent work under an employment relationship, service, voluntary work, or professional practice or internships for the Company; applications for such activities under Section 2(4) of the Act are also taken into account. This does not affect the possibility of submitting a report through the external reporting system of the Ministry of Justice.
4. Confidentiality and Protection of Whistleblowers
Only the designated person may access reports. The identity of the whistleblower and other protected information are confidential and may be disclosed only under the conditions laid down by applicable law. The Company prohibits retaliation against whistleblowers and other persons protected by law.
5. Procedure for Handling Reports
The designated person will acknowledge receipt of a report in writing within 7 days, unless the whistleblower expressly requests that no acknowledgement be sent or such acknowledgement would clearly reveal the whistleblower’s identity. The designated person will assess the report and inform the whistleblower of the outcome in writing within 30 days. In cases involving factual or legal complexity, this period may be extended by up to 30 days, no more than twice; the whistleblower will be informed of the extension and the reasons for it before the relevant deadline expires.
6. Anonymous Reports
The Company is not required to handle anonymous reports under the procedure established by Act No. 171/2023 Coll.; however, it may record such reports, assess their contents and take appropriate action depending on the circumstances. If the identity of an initially anonymous whistleblower subsequently becomes known, the whistleblower is entitled to protection under the conditions laid down by law.
7. External Reporting System
Reports may also be submitted directly to the Ministry of Justice of the Czech Republic without first using the Company’s internal reporting system. Information and reporting: https://oznamovatel.justice.cz/.
8. Knowingly False Reports
Submitting a knowingly false report constitutes an administrative offence under Section 23 of Act No. 171/2023 Coll., punishable by a fine of up to CZK 50,000. This provision does not apply to reports made in good faith that are subsequently found to be unsubstantiated.
9. Personal Data Protection
Personal data relating to reports are processed to the extent necessary to comply with legal obligations and protect the rights of the persons concerned, in accordance with Regulation (EU) 2016/679 (GDPR) and Act No. 171/2023 Coll. Access to reports and related data is restricted in accordance with the law.