In accordance with the EU Directive 2019/1937 on the protection of persons reporting breaches of Union law (hereinafter referred to as the “EU Directive”) and in accordance with Act No. 171/2023 Coll. (hereinafter referred to as the Act), ROI Hunter a.s. implements, as a mandatory entity, methods and rules for reporting unlawful conduct.
ROI Hunter has developed an internal directive for this issue. The directive establishes an internal whistleblowing system as a set of procedures for receiving, recording and processing reports, protecting the identity of the whistleblower and protecting the information contained in the report.
Basic concepts
Unlawful conduct
The subject of the report may be an unlawful conduct that has the characteristics of a criminal offence or misdemeanour with the upper limit of the fine rate for such an offence exceeding CZK 100,000, as well as conduct that violates legal regulations governing certain defined areas (e.g. corporate income tax, public procurement, competition, personal data processing, the environment, consumer protection and other areas defined exhaustively by law)
The Whistleblower
This means a person who reports information about an unlawful act of which he/she has become aware in connection with the work or other similar activity performed. Typically, this includes current and former employees, cooperating self-employed persons and their employees, or members of corporate bodies.
Receiving reports from individuals who do not perform work or a similar activity for ROI Hunter under Section 2 (3) (a), (b), (h), or (i) of the Act through the company's internal reporting system is excluded. These individuals may submit reports through the external reporting system of the Ministry of Justice.
Retaliatory measures
Whistleblowers are protected from retaliation by the company, i.e. conduct that is triggered by a whistleblower that may cause harm to the whistleblower.
Competent person
The competent person is responsible for receiving and assessing reports.
In ROI Hunter, the competent person is Mgr. Václav Karger.
Methods of submitting reports:
Any individual (whistleblower) who, in connection with their work or other similar activities, becomes aware of unlawful conduct (see definition above) by the company or its employees is entitled to file a report.
The whistleblower may submit a report in the following ways:
- Electronically - via the email address whistleblowing@roihunter.com, which only the competent person has access to;
- In writing – via postal services by registered letter to the address of the company's registered office. The submitted notification must be in a sealed envelope, clearly marked with the label "WHISTLEBLOWING – DO NOT OPEN," and must be addressed exclusively to the competent person.;
- In writing – personally delivered to the competent person;
- By phone – at the phone number +420770154771, during standard working hours (8:00-16:30), only the competent person has access to this phone number;
- In person – after agreement with the competent person on a specific date.
Note: An audio recording or recording of the oral notification shall be made that faithfully captures the content of the oral notification. An audio recording of an oral communication may be made only with the consent of the communicant. The competent person shall allow the whistleblower to comment on the recording or transcript of the audio recording, if made; the whistleblower's comments shall be attached to the recording or transcript.
Essentials of the notification
The name, surname and date of birth, or other information from which the identity of the whistleblower can be deduced, must be included in the report. Anonymous reports will not be investigated unless the identity of the whistleblower is subsequently identified.
The Ministry of Justice's external reporting system:
Reports can also be made through the external reporting system, i.e. by filing a report with the Ministry of Justice. The procedure for filing a report through the external notification system, including contact details, is published on the website: https://oznamovatel.justice.cz/informace-pro-oznamovatele/