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The company of MANUFAKTURA s.r.o. (hereinafter referred to as “the Company” or “the Employer”) prides itself on legal, ethical and transparent behaviour both internally towards its employees and externally towards business partners and third parties. At the same time, the Company does not tolerate illegal conduct, therefore it implements this internal rule in compliance with Act No 171/2023 Coll., on Whistleblower Protection, which describes the process of the internal reporting system and protects the whistleblower against retaliation or punishment.

1. Who is the whistleblower?

The whistleblower is a person who performs/performed their work or similar activities for the Company directly or indirectly, i. e. employees, contractors, trainees, job applicants. Whistleblowing can be anonymous.

2. What can be reported?

The whistleblower reveals information on possible illegal conduct, which happened or may happen, and which:

a) has the characteristics of a crime

b) has the characteristics of an offence with an upper limit of fines of at least CZK 100,000

c) violates the Act

d) infringes any other legislation or regulation of the EU in the following fields:

a. financial services, statutory audit and other authentication services, financial products and financial markets,

b. corporate income tax,

c. prevention of money laundering and terrorist financing,

d. consumer protection,

e. compliance with product requirements including their safety,

f. safety of transport, shipping and road traffic,

g. environmental protection,

h. safety of food and feed and protection of animals and their health,

i. radiation protection and nuclear safety,

j. protection of competition, public auctions and public procurement,

k. protection of internal order and security, life and health,

l. protection of personal data, privacy and security of electronic communication networks and information systems,

m. protection of the European Union´s financial interests, or

n. operation of the internal market, including protection of competition and state aid under European Union law.

The report contains name, surname and date of birth, or other information from which the whistleblower´s identity can be deduced; it is believed that the whistleblower´s identification data is true.

3. Instructions in case of a False Report

Protection against retaliation does not apply to a natural person who submitted a false report. Such a whistleblower commits an offence with fines up to CZK 50,000.

4. Method of Report

The report can be made through the following methods:

1) by means of the internal reporting system on whistleblowing@manufaktura.cz,

2) in writing to the address: MANUFAKTURA s.r.o., Nábřežní 90/4, Praha 5, 150 00 in a sealed envelope marked “WHISTLEBLOWING – DO NOT OPEN”.

3) orally by telephone or in person to a designated person (see contacts in Article 7 of this document),

4) next, it is possible to submit a report to the Ministry of Justice or to public authorities.

Oral reports can be recorded or transcribed, however, the audio recording can be made only with consent of the whistleblower. In case of reports in person, written records shall be made.

5. Deadline for Handling the Report

The whistleblower must be informed about receipt of their report submitted by the internal reporting system orally by telephone or in writing within 7 days. If the whistleblower asks for report in person, the meeting must take place within 14 days from the date when the whistleblower asked for it.

The designated person assesses the reasonableness of the report and informs the whistleblower in writing of the result within 30 days after receipt of the report. This period can be extended twice with each extension lasting 30 days. The designated person is obliged to inform the whistleblower in writing of the extended deadline and the reasons for its extension.

If the report is found reasonable, the designated person proposes measures to the Company.

The reports are stored for 5 years after their receipt.

6. Protection of the Whistleblower

The purpose of protection is taking measures to protect the whistleblower and their identity, to ensure protection against retaliation from the Company (termination of the contract, termination of employment, pay cut, disciplinary measures, hindering professional development, etc.). Protection applies also to persons that are close to the whistleblower, to those who provide assistance in collecting information, to colleagues, and others.

7. Designated Person

The designated person is a natural person without a criminal record, who accepts the whistleblowers´ reports. The designated person:

a) receives and assesses the reasonableness of the report submitted through the internal reporting system,

b) proposes to the obliged entity measures to remedy or to prevent the unlawful situation following the report, unless identity of the whistleblower is revealed this way,

c) complies with instructions of the obliged entity, unless they jeopardise or obstruct performance of its activities,

d) acts impartially in performance of its activities under this Act,

e) maintains confidentiality of the facts learnt during carrying out its activities under this Act, even after termination of these activities, unless a law provides otherwise.

The designated person cannot be penalized for proper performance of their duty under this Act.

The designated person is Mgr. Jana Čužnová, tel. +420 737 532 091.

In Prague, on December 1, 2023

Ing. Tomáš Kratochvíl
Managing Director


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