
whistleblowing
Whistleblowing reporting policy
Whistleblowing refers to the reporting of wrongdoing that occurs in connection with the whistleblower's work. The internal reporting system is designed to combat corruption and other undesirable behavior that contradicts the public interest.
What are the duties of the reporter?
Given the circumstances and information, the reporting person should have good reason to believe that the facts reported are authentic and true at the time of filing the report. It is not permissible to report knowingly false facts, as such behavior may be sanctioned.
The whistleblower should not engage in any conduct that could be considered a criminal offense when obtaining documents to support the reported facts. At the same time, they should act in the public interest and in good faith that the notification is based on credible facts and circumstances.
The whistleblower should be able to identify which area the illegal act relates to and should consider what verifiable information can document the reported act. High-quality and verifiable documents can positively influence the investigation process.
The authorized person for receiving and handling submissions is:
Alena Pytlíková (Whistleblowing Representative).
The notification must contain information about a possible illegal act:
- Criminal offenses, such as fraud or bribery,
- Violations of legal regulations or European Union laws,
- Any misconduct the whistleblower learned about in connection with their work or similar activities.
What is meant by work or other similar activity?
- Employment,
- Service,
- Self-employment,
- Exercise of rights in a legal entity,
- Role as a member of a body of a legal entity (e.g., elected body),
- Trust fund management,
- Volunteering,
- Professional experience, internship, or,
- Contractual obligations for supplying services, goods, or similar.
In accordance with the directive, work or other similar activity also includes applying for a job or similar activity.
Exceptions to the notification:
- Information threatening national security,
- Information about the activities of Czech intelligence services,
- Disclosure of information violating confidentiality, such as confessional secrecy.
Whistleblower Protection
The system is set up to protect the whistleblower’s identity. Only the person responsible for receiving and handling complaints is authorized to know the whistleblower's identity, and they are bound by confidentiality.
If the whistleblower had legitimate reasons to believe the violation is true, they are protected under the EU directive. Protection primarily includes the prohibition of retaliatory measures against the whistleblower or others related to them.
What can be considered retaliation:
- Exemption or exclusion from civil service or termination of employment,
- Non-renewal of a fixed-term contract,
- Dismissal from a senior or supervisory position,
- Disciplinary measures,
- Reduction in wages or denial of allowances,
- Discrimination, transfer, or reassignment,
- Changes in work hours or job evaluations,
- Failure to provide professional development,
- Medical opinions or occupational health requirements,
- Termination of contracts, or
- Interference with personality rights.
Procedure after notification
- The responsible person assesses whether the notification meets the conditions for processing under the EU directive and informs the notifier within 7 days.
- The responsible person investigates the information in the notification, and if confirmed, takes appropriate action, such as proposing corrective measures or forwarding the report to relevant authorities.
- The responsible person informs the notifier of the investigation outcome and proposed measures within 3 months.
Contact Options:
- By phone: +420 603 328 447, +420 568 839 107 (a written record will be taken of the interview)
- By email: oznamovatel@alsico.cz
- In person: A meeting can be arranged via phone or email.