Rolling bearings
Plain bearings
Linear products
Belts
Chain drives
Hoses
Power transmission
MaPRO
Lubrication & Industrial chemistry
Sealing elements
Tools & Devices
Retaining elements
Other products
CNC machining
Welding
Adoz linear centre
Manufacture of hoses and pipes
Oil bottling
Service of industrial gearboxes
Internet shopping, eshop
Emergency distribution
System interconnection
Whistleblowing
This text was translated by a machine. Please excuse any potential translation errors.
Rules for managing the internal reporting system of ADOZ, Ltd. according to Act No. 171/2023 Coll., on the protection of whistleblowers.
I. Scope of the Internal Reporting System
1.1 The internal reporting system fulfills the mandatory internal procedure and rules for submitting and receiving reports of unlawful conduct according to the law on the protection of whistleblowers, as well as assessing the validity of such reports and all other related activities.
1.2 The internal reporting system applies to the entire company and is binding for all its organizational units.
1.3 The internal reporting system applies to all company employees in an employment relationship and other affected individuals who perform work or similar activities for the company based on another contractual relationship, to job applicants, and to persons performing professional practice, internships, or other similar activities at the company, as well as to members of all company bodies.
1.4 The internal reporting system is also appropriately applied to other individuals who are in the position of an employee, a member of the body, or a partner of any legal entity that is a supplier of goods, services, or construction work, or are themselves such a supplier in the position of an independent entrepreneur (self-employed persons).
II. Purpose of the Internal Reporting System
2.1 The scope of the internal reporting system relates to the submission, receipt, investigation, and assessment of the validity of reports that:
a) have the characteristics of a criminal offense,
b) have the characteristics of an offense for which the law sets a fine rate, the upper limit of which is at least 100,000 CZK,
c) violate the law on the protection of whistleblowers or
d) violate another legal regulation of the Czech Republic or the European Union in the field of:
- financial services, mandatory audit, and other verification services, financial products, and financial markets,
- corporate income tax,
- prevention of money laundering and financing of terrorism,
- consumer protection,
- compliance with product requirements including their safety,
- safety of transport, carriage, and operation on roads,
- environmental protection,
- food and feed safety and animal and their health protection,
- radiation protection and nuclear safety,
- economic competition, public auctions, and public procurement,
- internal order and security, life and health protection,
- personal data protection, privacy, and security of electronic communications networks and information systems,
- protection of the financial interests of the European Union or
- functioning of the internal market including the protection of economic competition and state aid according to European Union law.
2.2 The whistleblower protection law does not affect the legal obligation to directly report committed criminal offenses to the criminal justice authorities, which are exhaustively listed in § 368 of the Criminal Code (hereinafter referred to as "reporting obligation").
III. Submitting and Receiving Reports
3.1 Reports of unlawful conduct within the internal reporting system can be submitted in accordance with the requirements of the whistleblower protection law in the following ways:
a) in writing in electronic form: adoz.wb@adoz.cz,
b) in writing in paper form sent as a letter to the company's postal address: ADOZ, Ltd., Výrobní 1441, 593 01 Bystřice nad Pernštejnem, with the envelope marked "DO NOT OPEN – for K. Hájková",
c) verbally – on the telephone number +420 771 161 589,
d) in person by agreement with the relevant person; in this case, the relevant person must personally accept the report from the whistleblower within a reasonable period, but no later than fourteen (14) days from the day the whistleblower requested it.
3.2 Reports can also be submitted through the external reporting system of the Ministry of Justice and/or directly to the relevant public authority, i.e., the Police of the Czech Republic, public prosecution offices, and/or the competent public administration bodies according to their jurisdiction.
3.3 The company designates a relevant person for receiving reports, investigating and assessing their validity, communicating with the whistleblower, proposing corrective measures, and for other activities according to § 11 and § 12 of the whistleblower protection law.
3.4 The relevant person will send the whistleblower a notification of the receipt of the report no later than seven (7) days from the date of submission. This does not apply only if:
a) the whistleblower explicitly requests the relevant person not to notify them of the receipt of the report, or
b) it is evident that notifying about the receipt of the report would reveal the identity of the whistleblower to another person.
3.5 If the content of the report does not constitute a report in the sense of § 2 of the Whistleblower Protection Act, the relevant person will no longer investigate it and will not begin to assess its validity, about which the whistleblower will also be notified within seven (7) days from the date of submission.
3.6 The relevant person is obliged to properly and timely record each submitted report in the report register, assign it the appropriate identifier, and further manage it exclusively under this identifier.
IV. Assessing the Validity of Reports
4.1 The relevant person is obliged to assess the validity of the report and inform the whistleblower in writing about the results of the assessment within thirty (30) days from the date of receipt of the report. In cases that are factually or legally complex, this period may be extended by up to another thirty (30) days, but no more than twice, i.e., the maximum duration for assessing the validity of a report may in exceptional cases amount to ninety (90) days from the date of submission. The relevant person is obliged to always inform the whistleblower in writing of the extension of the period and the reasons for its extension before it expires.
V. Measures to Protect Whistleblowers
5.1 In the context of managing the internal reporting system, as well as in related or other activities of all employees and/or members of the company's bodies, a strict prohibition on applying any retaliatory measures against whistleblowers applies.
VI. Other Provisions
6.1 In connection with the management of the internal reporting system at the company, personal data is processed, to which the relevant legal regulations apply, in particular the General Data Protection Regulation (also referred to as "GDPR").
6.2 The company, as the controller of personal data and as a subject obliged according to the law on the protection of personal data, processes personal data on the basis of a legal reason (title): fulfilling the legal obligations of the controller according to Art. 6(1)(c) GDPR. The retention period for personal data contained in the report and in documents related to the report is five (5) years from the date of receipt of the report.
6.3 Other rights and obligations of the company not mentioned in this document are governed by the relevant paragraphs of the whistleblower protection law.
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