Whistleblowing

Rules of the internal reporting system of ADOZ, s.r.o. (the “Company”) under Act No. 171/2023 Coll.,
on the Protection of Whistleblowers (the “WPA”).

I.
Scope of the Internal Reporting System

1.1 The internal reporting system sets out the binding internal procedure and rules for submitting and receiving reports of unlawful conduct under the WPA, for assessing the merits of such reports and for all related activities.

1.2 The internal reporting system applies to the entire Company and is binding on all its organizational units.

1.3 The internal reporting system applies to all employees of the Company in an employment relationship and to other natural persons who perform work or other similar activity for the Company under another contractual relationship, to job applicants and to persons completing professional practice, an internship or other similar activity at the Company, as well as to members of all Company bodies.

1.4 The internal reporting system also applies, as appropriate, to other natural persons who are employees, members of a body or shareholders of any legal entity that supplies goods, services or construction work, or who are themselves such a supplier as independent entrepreneurs (self-employed persons).

II.
Purpose of the Internal Reporting System

2.1 The internal reporting system covers the submission, receipt, investigation and assessment of the merits of reports which:
a) have the characteristics of a criminal offence,
b) have the characteristics of an administrative offence for which the law sets a fine with an upper limit
of at least CZK 100,000,
c) violate the WPA, or
d) violate another legal regulation of the Czech Republic or a regulation of the European Union in the
area of:

financial services, statutory audit and other assurance services, financial products and financial markets,
corporate income tax,
prevention of money laundering and terrorist financing,
consumer protection,
compliance with product requirements, including product safety,
transport safety and road traffic,
environmental protection,
food and feed safety and animal health and welfare,
radiation protection and nuclear safety,
competition, public auctions and public procurement,
protection of internal order and security, life and health,
protection of personal data, privacy and security of electronic communications networks and information systems,
protection of the financial interests of the European Union, or
functioning of the internal market, including the protection of competition and state aid under European Union law.

2.2 The WPA does not affect the statutory obligation to report directly to law enforcement authorities the criminal offences exhaustively listed in Section 368 of Act No. 40/2009 Coll., the Criminal Code.

III.
Submitting and Receiving Reports

3.1 Reports of unlawful conduct may be submitted through the internal reporting system in the following ways:
a) in writing, electronically: adoz.wb@adoz.cz,
b) in writing, on paper, sent by post to the Company’s address: ADOZ, s.r.o., Výrobní 1441, 593 01 Bystřice nad Pernštejnem, Czech Republic, with the envelope marked: “NEOTVÍRAT – k rukám pověřence pro lidská práva” (Do not open – for the Human Rights Officer),
c) orally, by phone: +420 771 161 589,
d) in person, by appointment with the Designated Person; in this case, the Designated Person must receive the report in person within a reasonable time, but no later than fourteen (14) days from the date on which the whistleblower requested it.

3.2 Where the statutory conditions are met, a report may also be submitted through the external reporting system of the Ministry of Justice of the Czech Republic (oznamovatel.justice.cz) and/or directly to the competent public authority, i.e. the Police of the Czech Republic, the public prosecutor’s offices and/or the competent public administration authorities.

3.3 The Company has appointed a Designated Person to receive reports, investigate them and assess their merits, communicate with the whistleblower, propose remedial measures and perform other activities under Sections 11 and 12 of the WPA. The Designated Person also serves as the Human Rights Officer:

Květoslava Hájková, e-mail: adoz.wb@adoz.cz, phone: +420 771 161 589

3.4 The Designated Person sends the whistleblower a confirmation of receipt of the report no later than seven (7) days from the date of its submission. This does not apply only where:
a) the whistleblower expressly asks the Designated Person not to notify them of receipt, or
b) it is clear that notification of receipt would reveal the whistleblower’s identity to another person.

3.5 If, in terms of its content, the submission is not a report within the meaning of Section 2 of the WPA, the Designated Person does not investigate it further or assess its merits, and informs the whistleblower accordingly within seven (7) days from the date of its submission. This does not apply to a complaint under Article VI; such a complaint is handled under Article VI.

3.6 The Designated Person must properly and promptly record each report in the register of reports, assign it an identifier and handle it exclusively under this identifier.

IV.
Assessment of the Merits of Reports

4.1 The Designated Person must assess the merits of the report and inform the whistleblower in writing of the results within thirty (30) days from the date of receipt of the report. In factually or legally complex cases, this period may be extended by up to thirty (30) days, but no more than twice, i.e. the maximum period for assessing the merits of a report may exceptionally be ninety (90) days from the date of its submission. The Designated Person must always inform the whistleblower in writing of the extension and the reasons for it before the period expires.

V.
Measures to Protect Whistleblowers

5.1 Within the operation of the internal reporting system, as well as in related or other activities of all employees and/or members of the Company’s bodies, any retaliatory measures against whistleblowers are strictly prohibited.

VI.
Extended Grievance Mechanism

6.1 In addition to reports under the WPA, the Designated Person also receives, through the channels under point 3.1, complaints concerning violations of the Company’s Code of Conduct, in particular in the areas of human rights and working conditions, environmental protection and unethical business practices.

6.2 A complaint may be submitted by any person affected by the Company’s activities, in particular employees, agency workers, suppliers and their employees, customers, subcontractors and local
communities.

6.3 A complaint may also be submitted anonymously. The Designated Person sends a confirmation of receipt and notification of the outcome only if the complainant provides contact details.
6.4 The periods under points 3.4 and 4.1, the duty of confidentiality, the protection of identity and the prohibition of retaliatory measures apply to complaints as appropriate.

6.5 If a complaint is justified, the Designated Person consults the complainant or their representative, as needed, when proposing remedial measures.

6.6 A complainant who disagrees with the outcome may appeal to the Managing Director within 15 days of its delivery; the Managing Director assesses the appeal within 30 days. The effectiveness of the reporting and grievance mechanism is evaluated at least once every 12 months.

VII.
Other Provisions

7.1 The operation of the Company’s internal reporting system involves the processing of personal data subject to the relevant legislation, in particular the General Data Protection Regulation (the “GDPR”).

7.2 The Company, as the personal data controller and as an obliged entity under the WPA, processes personal data on the legal basis of compliance with a legal obligation of the controller under Article 6(1)(c) GDPR. Personal data contained in reports and in documents related to reports are retained for
five (5) years from the date of receipt of the report.

7.3 Other rights and obligations of the Company not set out in this document are governed by the relevant provisions of the WPA.

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