Whistleblowing

"Rules for Submitting a Notification Pursuant to Act No. 171/2023 Coll. on the Protection of Whistleblowers"

Who Can Submit a Notification:

Anyone who has performed or is performing work or similar activities for ATODA spol. s r.o. ("Company") either directly or indirectly, or who has been or is in contact with the Company in connection with the performance of work or similar activities, and who has become aware of any illegal act ("Whistleblower") that violates the relevant legal regulation and reports or has reported this fact to the Company (hereinafter referred to as "Notification").

The Company excludes the acceptance of notifications from persons who do not or have not performed work or other similar activities for the Company pursuant to Section 2(3)(a), (b), (h), or (i) of the Act.

What Can Be Reported Through a Notification:

Possible illegal acts within the Company that:

• Constitute a criminal offense
• Constitute a misdemeanor for which the law prescribes a fine with an upper limit of at least CZK 100,000
• Violate the Act
• Violate another legal regulation or a regulation of the European Union in the area of:

• Financial services, statutory audit and other assurance services, financial products and financial markets
• Corporate income tax  
• Prevention of money laundering and terrorist financing
• Consumer protection
• Compliance with product requirements, including their safety  
• Safety of transport, carriage and operation on public roads
• Environmental protection
• Safety of food and feed and protection of animals and their health
• Radiation protection and nuclear safety
• Competition, public auctions and public procurement
• Protection of internal order and security, life and health
• Protection of personal data, privacy and security of electronic communications networks and information systems  
• Protection of the financial interests of the European Union, or
• The functioning of the internal market, including the protection of competition and state aid under European Union law  

Responsible Person

Vít Rajnoch has been appointed as the responsible person for assessing received Notifications.

How to Submit a Notification

• By email to vrajnoch@amberit.cz
• By telephone on +420 775 173 504
• In person to the Responsible Person, whereby the submission of a personal notification will be enabled without undue delay, at the latest within 14 days, at the request of the Whistleblower.
• In writing by post to the address Lidická tř. 2331/6a, 370 01 České Budějovice, Czech Republic, to the attention of: Vít Rajnoch, with the envelope marked "Whistleblowing – Do Not Open".

The responsible person shall notify the Whistleblower of the receipt of the Notification within 7 days of its receipt. The responsible person shall assess the validity of the notification and shall notify the Whistleblower in writing of the results of the assessment within 30 days of the date of receipt of the Notification. In cases that are factually or legally complex, this period may be extended by up to 30 days, but no more than twice. The Responsible Person shall notify the Whistleblower of the extension of the deadline and the reasons for its extension before the deadline expires.

In accordance with Section 2 of the Act, the Notification shall contain the name, surname and date of birth, or other information from which the identity of the Whistleblower can be inferred. It shall also contain information about the possible illegal act that has occurred or is about to occur within the Company.

The protection of the Whistleblower applies to any Whistleblower who makes a Notification and meets the criteria laid down by the Act, in particular that they have reasonable grounds to believe that their Notification is based on true information. The Whistleblower should, having regard to the circumstances and the information available to them at the time of the notification, have a compelling reason to believe that the facts reported by them are authentic and true. It is therefore not possible to report facts that are knowingly false. Such conduct may be sanctioned. The Whistleblower should be able to identify the areas to which the illegal act relates and to consider what verifiable information about the reported illegal act they can provide. The extent and quality of the information provided may affect the manner in which the Notification is investigated.

Notifications will be assessed objectively and independently by the Responsible Person. On the basis of the facts established, remedial measures will be taken if necessary.

Notification to the Ministry of Justice

Under the Act, certain illegal acts may also be reported to the Ministry of Justice at the following website: https://oznamovatel.justice.cz/chci-podat-oznameni/