Internal whistleblowing system

 

The internal whistleblowing system is intended for employees of the company and other persons who, in the course of their work, become aware of illegal conduct within the company's operations.

You can submit a notification in the following ways

 

Telephone

Call the dedicated number: +420 771 288 565

 

Email
Write to the dedicated e-mail address: marketa.valtusova@atona.cz

In writing to
Write the notification to: Atona s. r. o., Poříčí 44/2428, 67801 Blansko

Personal meeting
Arrange a personal meeting with: Markéta Valtusová
 
 
The notification must include your first name, surname, date of birth, job position. Anonymous submissions will not be investigated.

The Company does not exclude the acceptance of notifications from a person who does not perform work or other similar activities for the company pursuant to Section 2(3)(a), (b), (h) or (i) of the Whistleblower Protection Act No. 171/2023 Coll.

External notification system

 
If an internal reporting channel has not been set up at the company or is not functional (e.g., the whistleblower believes that their report will not be investigated, their identity will not be protected, they would be at risk of retaliation, etc.), the whistleblower may file a report directly through the external reporting system established by the Ministry of Justice of the Czech Republic. The submission of a notification to the Ministry is not conditional on the initial submission of a notification through the internal notification system. It is entirely up to the whistleblower to decide what course of action to take.
 
The whistleblower may submit the notification in person, by telephone or in writing.

 

How whistleblowing is defined by Act No. 171/2023 Coll.

What is a notification

 

Section 2
(1) The notification shall contain information about a possible violation that has occurred or is about to occur in relation to a party for which the whistleblower has performed or is performing, even indirectly, work or another similar activity, or in relation to a party with which the whistleblower has been or is in contact in connection with the performance of work or another similar activity and which
(a) has the characteristics of a criminal offence,
b) has the characteristics of a misdemeanour for which the law stipulates a fine of at least CZK 100,000,
(c) violates this Act; or
(d) infringes another legal regulation or a regulation of the European Union in the field of
1. financial services, due diligence and other assurance services, financial products and financial markets
2. corporate income tax,
3. prevention of money laundering and terrorism financing,
4. consumer protection,
5. compliance with product requirements, including product safety,
6. transport, traffic and road safety,
7. environmental protection,
8. food and feed safety and animal health protection,
9. radiation protection and nuclear safety,
10. competition, public auctions and public procurement,
11. protection of internal order and security, life and health,
12. protection of personal data, privacy and security of electronic communications networks and information systems,
13. protection of the financial interests of the European Union, or
14. functioning of the internal market, including the protection of competition and state aid under European Union law.
(2) The notification shall contain the first name, surname and date of birth, or other information from which the identity of the whistleblower can be inferred; information concerning the identity of the whistleblower shall be deemed to be true. The notification need not contain the information referred to in the first sentence if it is made by a person whose identity is known to the competent person pursuant to Section 10 or to the public servant pursuant to Section 13.
(3) For the purposes of this Act, work or another similar activity means
(a) dependent work carried out in a basic employment relationship,
(b) service,
(c) self-employment,
(d) exercise of rights attached to participation in a legal entity,
(e) exercise of the office of a member of a body of a legal entity,
f) performance of tasks within the scope of the activities of a legal entity, in its interest, on its behalf or on its account,
(g) administration of a trust fund,
(h) volunteering,
(i) professional practice, internship, or
(j) exercise of rights and obligations arising from a contract, the subject of which is the provision of supplies, services, construction work or another similar performance.
(4) For the purposes of this Act, work or another similar activity includes applying for work or other similar activity.
What are the whistleblower's obligations

 

In the light of circumstances and information available to them at the time of the notification, the whistleblower should have reasonable grounds to believe that the facts notified or disclosed by them are authentic and true. It is therefore not possible to report facts that are knowingly false. Such behaviuor may be sanctioned.
 
In obtaining documents to substantiate the reported facts, the whistleblower should not commit an act that could constitute a criminal offence.
 
The whistleblower should act in the public interest and in good faith that the report they are making is based on credible facts and evidence.
 
The whistleblower should be able to identify the area of infringement and consider what verifiable information they can provide about the reported infringement.
The extent and quality of the submitted information can have a positive influence on the manner in which a notification is investigated.
How is the whistleblower protected

 

Access to the notification systems is only granted to specially authorised staff, known as competent persons, who are obliged to protect the identity of the whistleblower at all times. The identity of the whistleblower may not be disclosed to anyone else without their express consent. The obligation of confidentiality does not only apply to the identity of the whistleblower, but also to any other information from which their identity could be directly or indirectly determined.
 
The legal system does not allow for any legal retaliation for reporting a violation, and instead protects the whistleblower. The employer for whom the whistleblower performs work or other similar activity is obligated to prevent any retaliation against whistleblowers, including the threat or attempted threat of retaliation.
How soon will the notification be dealt with

 

Within 7 calendar days, the whistleblower must receive confirmation that the notification has been received, and no later than 30 days after receipt of the notification, the whistleblower should receive notification of how the notification has been assessed. The investigation period can be extended twice by 30 days in complicated cases (to a total of 90 days).