Whistleblowing

The notifier is the natural person who made the notification according to the APW. The notification must contain data on the name, surname and date of birth or other data from which it is possible to deduce the identity of the notifier; this information may not be included in the notification if it was submitted by a person whose identity is known to the relevant person.

The company excludes receiving notifications from a person who does not perform work or other similar activities for it in accordance with § 2 paragraph 3 letter a), b), h) or i) APW.

The conditions for the emergence of the right to protection of the whistleblower and other persons set out in section 4, paragraph 2 of the APW and the scope and content of this protection are specified in the APW.

Protection against retaliatory measures does not belong to a person who made a knowingly false report or an anonymous report, a person who made a report other than through the internal reporting system in the manner specified in this internal regulation or the Ministry of Justice in accordance with the APW, as well as a person who made a report outside APW mode.

With the consent of the notifier, the competent person shall make an audio recording of an oral notification (made by telephone or in person) or, if consent to recording is not granted, a recording or transcript that faithfully captures the essence of the oral notification. The relevant person shall allow the notifier to comment on the recording or transcript of the notification, if it has been taken; the notifier’s statement shall be attached to the record or transcript.

The notifier shall be notified by the relevant person who received the notification according to the APW in any of the above ways without undue delay, no later than 7 days from the date of receipt of the notification, unless:

• the notifier explicitly requests the relevant person not to inform him of the receipt of the notification, or
• it is obvious that the identity of the notifier would be revealed by the notification of receipt of the notification.

The relevant person will notify the notifier of the results of the assessment of the reasonableness of the notification within 30 days from the date of receipt of the notification. In factually or legally complex cases, this period can be extended by up to 30 days, but no more than twice. The notifier will be notified in writing of the extension of the deadline and the reasons for its extension before it expires, unless:

• the notifier explicitly asked the relevant person not to inform him about the extension of the above-mentioned deadline and the reasons for its extension, or
• it is obvious that the notification of the extension of the above-mentioned deadline and the reasons for its extension would reveal the identity of the informant.

The notifier will be informed without undue delay that it is not a notification according to ZOO, if the relevant person discovers this when assessing the reasonableness of the notification, as well as that the notification is not evaluated as reasonable, in which case the notifier will also be informed of the right to file a notification at the Ministry of Justice.

Any notification to the whistleblower pursuant to this section shall be made by the relevant person in writing to the address of residence or to the e-mail address that the whistleblower communicated to them, or which the relevant person has at their disposal.

The relevant person keeps records of received notifications in electronic form, to the extent of

• the date of receipt of the notification
• name, or names, surname, date of birth and contact address of the informant, if these data are known to the relevant person
• a summary of the content of the notification and the identification of the person against whom the notification was directed, if his identity is known
• the date of completion of the assessment of the reasonableness of the notification by the competent person and its result.

The relevant person shall keep the notification submitted through the internal notification system and the documents related to the notification for a period of 5 years from the date of receipt of the notification.

Only the appropriate person has access to records, documents related to the notification and stored notifications.