PROTECTION OF WHISTLEBLOWERS REPORTING UNLAWFUL OR UNETHICAL CONDUCT
NIVEKO s.r.o. (the “Company”) prides itself on its responsible behaviour towards its customers, partners and employees and on its respect for legal, ethical and moral values.
We do not tolerate unlawful or unethical behaviour and do not let it go without consequences. In order to prevent and detect such conduct and to provide whistleblowers with the guarantee that if they report facts indicating that someone has committed such conduct in the designated manner, they will not be sanctioned in any way, we have introduced an >internal reporting system that ensures the confidential assessment of each report in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers (the “Act”).
All reports will be accepted and independently assessed by the relevant person. The contact details for this person can be found below on our Company's website. You may contact him in person or fill out the questionnaire on this website and send it to us by mail or email. Before filing your report, please make sure that you are reasonably certain that your suspicions are justified. Only a person who submits a report pursuant to Section 2 of the Act is classed as a whistleblower under this Act and need have no fear of leaks or retaliation.
1. Who is a whistleblower under the Act, i.e. who can submit a report through the Company's internal reporting system?
Company employees and other natural persons who perform work or other similar activities for the Company pursuant to Section 2 of the Act (“Whistleblowers”) may submit a report through the internal reporting system. The internal reporting system cannot be used by persons who do not perform work and other similar activities for the Company under the Act.2. What is the purpose of the internal reporting system?
Whistleblowers may use the internal reporting system to report suspected unlawful or unethical conduct that violates the legal provisions set out in the Act. Whistleblowers and their reports specified in the Act are then guaranteed the rights arising from the Act; in particular, this means that the identity of the Whistleblowers is protected and they are also protected from retaliatory measures. All reports are handled confidentially and the results of the investigation are communicated to the Whistleblower if the Company has their contact details and they wish to be notified. As provided by the Act, the Company is not obliged to deal with anonymous reports.3. What information should the report contain
In order to assess a report, we need as much information as possible about the incident being reported, in particular:
- When and where did the incident occur? How long did it last?
- Who (which persons) are affected?
- What did it specifically concern.
- When and how did you hear about the matter? Does anyone else know about it? Has anyone been informed about it yet (by yourself/another person)?
- Documents/other evidence you may have on the matter.
4. How to file a report through the internal reporting system?
a) In person
You may contact the responsible person to file a personal report in a face-to-face meeting: Ing. Šimon Janča, Managing Director of NIVEKO s.r.o., e-mail: simonjanca@niveko.cz
b) In writing
The easiest way to file a report is to complete the questionnaire available for download on this website below and send it to us by email or post to the address below.You can send us the report by post to NIVEKO s.r.o., for the attention of Ing. Šimon Janča, Managing Director, Nivnická 2716, 688 01 Uherský Brod, Czech Republic, marked “CONFIDENTIAL, DO NOT OPEN, FOR THE ATTENTION OF THE RESPONSIBLE PERSON” or to the e-mail of the responsible person, simonjanca@niveko.cz, with the subject “REPORT FOR THE ATTENTION OF THE RESPONSIBLE PERSON”..
5. Our procedure after receiving the report
If you would like to be notified of receipt of your report and the results of the assessment, please leave your contact details or write to us to let us know that you do not wish to be notified. However, we may wish to ask you for additional information that could help us to assess the matter more quickly. That is another reason why it is important that we stay in contact with each other.6. Treatment of personal data when recording and archiving reports
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR Regulation") and other relevant legislation relating to personal data protection. We have established an internal reporting system based on the Act and on our Company's legitimate interest in identifying instances of unlawful or unethical conduct and taking appropriate remedial action.We keep records of the reports we receive in accordance with Section 21 of the Act containing the following data:
a) the date of receipt of the report, b) the name, surname, date of birth and contact address of the Whistleblower, or other information from which the identity of the Whistleblower can be inferred, if known, c) a summary of the content of the report and identification of the subject of the report, if their identity is known to us, d) the date of completion of the assessment of the validity of the report or the assessment of the report by the responsible person and the outcome of the assessment.
Reports received and report-related documents are archived for 5 years after receipt.
In the case of reports made through the Company's internal reporting system, only the relevant persons of the Company have access to these records. Only the authorised employee of the Ministry has access to reports submitted to the Ministry of Justice of the Czech Republic.