Whistleblowing
Information for whistleblowers regarding unlawful conduct reported through the internal reporting system of AQUAdem, s.r.o. (whistleblowing)
Introductory Information
The company AQUAdem, s.r.o., ID No.: 25309340, with its registered office at Brno-Chrlice, Tovární 739/1, Postcode 64300, file no. C 24400 maintained by the Regional Court in Brno (hereinafter referred to as the "Company"), operates an internal reporting system and ensures the protection of whistleblowers based on legal obligations imposed on the Company as a so-called obliged entity under Act No. 171/2023 Coll., on the Protection of Whistleblowers, as amended (hereinafter also referred to as "WPA").
To ensure compliance with the obligations of the WPA, the Company has issued a binding Directive on the Management of the Internal Reporting System (whistleblowing) (hereinafter also referred to as the "Directive").
Who can file a report of unlawful conduct
A whistleblower who can file a report through the Company's internal reporting system is any natural person who performs or has performed work or other similar activity for the Company and files the report in this work context as:
- a) an employee of the Company who performs work for the Company in an employment relationship or on the basis of an agreement on work activity or an agreement on the performance of work,
- b) a former employee of the Company,
- c) a person who performs or has performed volunteer activities for the Company,
- d) a person who performs or has performed professional practice or an internship at the Company.
In accordance with Section 9(2)(a) of the WPA, the Company has excluded the possibility of receiving reports from persons under Section 2(3)(c), (d), (e), (f), (g), and (j) and further under Section 2(4) of the WPA.
Possible methods of filing a report of unlawful conduct
A report of unlawful conduct can be filed within the Company's internal reporting system in accordance with the requirements of the WPA in the following ways:
- a) in writing in electronic form via an e-mail sent to the e-mail address mak@aquadem.cz;
- b) in writing in hard copy sent as a postal shipment to the Company's postal address: Brno-Chrlice, Tovární 739/1, Postcode 64300, provided that the envelope must be marked with the words: "Do not open - to the hands of the relevant person according to the WPA";
- c) orally - at the telephone number 724 828 133, on working days MON – FRI between 9:00 AM – 3:00 PM;
- d) in person by agreement with the relevant person; in this case, the relevant person must receive the report in person from the whistleblower within a reasonable period, but no later than fourteen (14) days from the date the whistleblower requested it.
A natural person has the right to whistleblower protection under the WPA and this Directive if:
- a) the conditions under the WPA and the said Directive are met in connection with their report and if
- b) this person has reasonable grounds to believe that the information reported by them was true at the time of reporting and that the report was necessary to detect unlawful conduct.
A fine of up to CZK 50,000 may be imposed for a knowingly false report.
Who is the relevant person for receiving and handling reports
Only the relevant person is authorized to receive reports, assess their validity, and follow other related procedures within the internal reporting system.
The relevant persons at the Company are:
Ms. Martina Koutná
Tel. +420 724 828 133, e-mail: mak@aquadem.cz, delivery address: AQUAdem, s.r.o., Tovární 739/1, 643 00 Brno - Chrlice
Mr. Václav Mika
Tel. +420 602 742 460, e-mail: mik@aquadem.cz, delivery address: AQUAdem, s.r.o., Tovární 739/1, 643 00 Brno - Chrlice
Other channels and options for filing a report of unlawful conduct
If the legal conditions are met, a report can also be filed through the external reporting system of the Ministry of Justice and/or directly with the relevant public authority, i.e., the Police of the Czech Republic, the Public Prosecutor's Office, and/or the substantively relevant state administration bodies according to their jurisdiction (e.g., the Czech Environmental Inspectorate, the Office for Personal Data Protection, etc.). This applies, under the conditions set by the WPA, to all persons under Section 2(3) and (4) of the WPA.
In this case, the report is received, investigated, and assessed by the Ministry of Justice or another relevant public authority.
External channel for reporting unlawful conduct:
Ministry of Justice of the Czech Republic
Vyšehradská 424/16
128 10 Nové Město
Application: https://oznamovatel.justice.cz/chci-podat-oznameni/
E-mail: oznamovatel@msp.justice.cz
Tel.: 221 997 840
