Whistleblowing

Rules for filing a notification under Act No. 171/2023 Coll., on the protection of whistleblowers

Any employee of the company ALBA CR spol. s r.o., Masarykovo náměstí 26, Škvorec, 250 83, ID: 62909134 (hereinafter referred to as “ALBA”), and/or a natural person who, in connection with their work or other similar activity (e.g., in independent gainful activity or activity based on a contract between ALBA company and its supplier), performed/performs for ALBA company (hereinafter referred to as “Whistleblower”), may submit a report on possible unlawful conduct in accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers (hereinafter referred to as the “Act”), regarding actions within ALBA company that may constitute a criminal offense or misdemeanor, or may violate a legal regulation or regulation of the European Union (hereinafter referred to as the “Notification”).

a) Person in charge of receiving and processing the Notification: the person in charge of receiving and processing the Notification in accordance with the Act is Sabina den Brinker (“Competent Person”).

b) Ways of submitting Notifications (Internal reporting system): Notifications regarding possible unlawful conduct within ALBA company can be submitted in accordance with the Act by the following means:

  • Electronically – email: sabina.denbrinker@alba.progresium.cz
  • In writing – by letter marked “For the attention of Sabina den Brinker,” sent by mail to the address: ALBA CR spol. s r.o., Masarykovo náměstí 26, 250 83 Škvorec, Czech Republic
  • By phone – at +420 732 363 545. The phone call will not be recorded; ALBA will provide a concise record of the call. You will have the opportunity to review, correct, and approve the call record. In the absence of the Competent Person, you can use another method to submit the Notification.
  • In person – You can arrange a personal meeting with the Competent Person via email or phone. A concise record of the meeting will be made during the personal conversation. You will have the opportunity to review, correct, and approve this record with your signature.

Notifications can also be made anonymously.

c) Deadlines for informing the Whistleblower of measures taken

If ALBA is aware of your identity (contact details) and you do not reject the notification in advance, or if the notification would lead to the disclosure of your identity or would thwart the purpose of the Notification, ALBA will inform you as the Whistleblower:

  • Setting a date for a personal meeting (within 14 days of receiving your request): immediately,
  • About the acceptance of your Notification: within 7 days,
  • About the justification of your Notification: within 30 days from the date of acceptance, in complex cases, the deadline can be extended twice, up to 90 days,
  • About the rejection of your Notification (no unlawful act or notification based on false information): without undue delay,
  • About the measures taken: without undue delay after their adoption.

d) Protection of the Whistleblower

The Relevant Person will maintain strict confidentiality regarding your identity, information about other natural persons, and information provided in the Notification. As a Whistleblower, you are entitled to protection against any retaliatory measures within the meaning of the Act, including the mere threat of such measures.

e) External reporting system institutions for alternative submissions (External reporting system)

In addition, you can alternatively submit a Notification to the Ministry of Justice, even if you have doubts about whether the facts discovered constitute unlawful conduct within the meaning of the Act. The Ministry of Justice accepts Notifications at: Ministry of Justice of the Czech Republic, Vyšehradská 16, Prague 2, ZIP code 128 10, email: oznamovatel@msp.justice.cz, tel. +420 221 997 840.