Whistleblowing

 1. Introductory Information 

ALUKOV a.s. operates an internal reporting system and ensures the protection of whistleblowers based on legal obligations imposed on the company as an obliged entity pursuant to:

• Act No. 171/2023 Coll., on Whistleblower Protection

(hereinafter referred to as the “Whistleblower Protection Act” or the “Act”).

To ensure compliance with the obligations under the Whistleblower Protection Act, a binding internal directive has been issued:

• Directive on the Internal Reporting System and Whistleblower Protection at ALUKOV a.s. (hereinafter also referred to as the “Directive”).

Through the internal reporting system of ALUKOV a.s., a report of unlawful conduct (hereinafter referred to as the “Report”) can be submitted by a duly authorized natural person (hereinafter referred to as the “Whistleblower”), provided the set conditions are met, concerning unlawful conduct that the Whistleblower has become aware of in connection with their work or other similar activity performed for the company.

 2. Types of Reports That Can Be Submitted Through the Internal Reporting System

Reports that can be submitted via the internal reporting system of ALUKOV a.s. (hereinafter also “ALUKOV a.s.”) include those that:

• contain information about possible unlawful conduct that has occurred or is likely to occur at ALUKOV a.s., where the Whistleblower has worked or is working, or at an entity with which the Whistleblower was or is in contact in the course of performing work or similar activity (in a work context), and which:

1. constitutes a criminal offense,
2. constitutes an administrative offense punishable by a fine of at least CZK 100,000,
3. violates the Whistleblower Protection Act, or
4. violates other legislation of the Czech Republic or European Union regulations in the areas of:

     1. financial services, statutory audits and other verification services, financial products and markets,
     2. corporate income tax,
     3. anti-money laundering and counter-terrorism financing,
     4. consumer protection,
     5. product compliance, including product safety,
     6. transport, transit, and road traffic safety,
     7. environmental protection,
     8. food and feed safety and animal health protection,
     9. radiation protection and nuclear safety,
     10. competition, public auctions, and public procurement,
     11. internal order and security, life and health protection,
     12. personal data protection, privacy and cybersecurity,
     13. protection of the EU’s financial interests, or
     14. functioning of the internal market, including competition and state aid under EU law.

3. Who Can Submit a Report of Unlawful Conduct

A Whistleblower who can submit a Report via ALUKOV a.s.’ internal reporting system is any natural person who performs or has performed work or a similar activity for ALUKOV a.s., even indirectly, and who submits the Report in this work-related context as:

     a) an employee working under an employment contract or agreement on work activity/performance;
     b) a former employee of the company;      c) a job applicant at the company;
     d) a person undertaking or having undertaken an internship, training, or volunteering at the company;
     e) a person who is or was a partner of the company;
     f) a member of a statutory or other company body;

The person is entitled to whistleblower protection under the Whistleblower Protection Act and the internal Directive if:

     a) the above conditions are met, and simultaneously if
     b) the person had reasonable grounds to believe the information reported was true at the time of submission.

The Whistleblower Protection Act and this internal Directive do not affect the legal obligation to report certain criminal offenses directly to law enforcement authorities, as defined in Section 368 of the Criminal Code (e.g., murder, grievous bodily harm, etc.).

4. How to Submit a Report of Unlawful Conduct

A Report of unlawful conduct can be submitted via ALUKOV a.s.’ internal reporting system in accordance with the Whistleblower Protection Act using the following methods:

     a) in writing as a data message sent electronically to the email address whistleblowing@alukov.cz;
     b) in writing in paper form sent as a postal letter to the company address: ALUKOV a.s., Orel No. 18, 538 21 Slatiňany, with the envelope marked: “Do not open – to the attention of Mrs. Sylva Novotná” or “Do not open – to the attention of Mr. Jiří Tichý”
     c) by phone at 733 788 505 (Sylva Novotná) or 739 684 902 (Jiří Tichý).
     d) in person by arrangement with the Designated Person; in this case, the Designated Person shall receive the Report within a reasonable time, but no later than fourteen (14) days from the request.

Repeated Reports from the same Whistleblower on the same matter are inadmissible and will not be re-investigated. The Whistleblower will be informed of this with a brief justification. This does not apply if the new Report contains additional facts or information compared to the previous one.

5. Who is the Designated Person for Receiving and Processing Reports 

Only the Designated Person is authorized to receive Reports, assess their legitimacy, and take further actions within the internal reporting system.

At ALUKOV a.s., there are two Designated Persons:

Sylva Novotná

e-mail: s.novotna@alukov.cz

Tel: 733 788 505

Substitute Designated Person:

Jiří Tichý

e-mail: j.tichy@alukov.cz

Tel: 739 684 902

When receiving and assessing the legitimacy of Reports, the Designated Person always acts independently, impartially, and autonomously and is entitled to request necessary information and documents from all departments and employees of ALUKOV a.s., as well as other forms of cooperation.

The Designated Person shall ensure that the contacted employees are not made aware of the contents of the Report and that no information that could reveal the identity of the Whistleblower is disclosed.

6. Time Limits for Notifying the Whistleblower and Assessing the Report

The Designated Person shall notify the Whistleblower of the receipt of the Report within seven (7) days of submission.

This does not apply if:

     a) the Whistleblower explicitly requests not to be notified of the receipt; or
     b) such notification could reveal the identity of the Whistleblower to others.

The Designated Person must assess the legitimacy of the Report and notify the Whistleblower of the results in writing within thirty (30) days of receipt.

In factually or legally complex cases, this period may be extended by an additional thirty (30) days, up to two times. Thus, the maximum period for assessment may be ninety (90) days from submission in exceptional cases.

The Designated Person shall inform the Whistleblower in writing of the extension and the reasons before the original deadline expires.

7. Prohibition of Retaliation Against Whistleblowers

In the operation of the internal reporting system, as well as in all related or other activities of ALUKOV a.s. employees and/or members of its governing bodies, a strict prohibition on any form of retaliation against Whistleblowers applies.

Retaliation refers to any action or omission in connection with the Whistleblower’s work or similar activity, triggered by the submission of a Report, which may harm the Whistleblower.

If the above conditions are met, retaliation includes, for example, termination or non-renewal of employment, reduction in salary or bonuses, denial of personal allowances, transfer to another job, denial of professional development, contract termination, or infringement of personal rights.

8. Possibility to Use Other Channels for Reporting Unlawful Conduct 

Reports can also be submitted, under legal conditions, via the external reporting system of the Ministry of Justice and/or directly to a competent public authority such as the Police of the Czech Republic, the Public Prosecutor’s Office, or relevant public administration bodies (e.g., Czech Environmental Inspectorate, Office for Personal Data Protection, etc.).

In such cases, the Ministry of Justice or another competent public authority receives, investigates, and assesses the Report.

External reporting channel:

Ministry of Justice of the Czech Republic

Vyšehradská 424/16

128 10 Nové Město

Application: https://oznamovatel.justice.cz/chci-podat-oznameni/

E-mail: oznamovatel@msp.justice.cz

Tel.: +420 221 997 840