Part I: Policy details
1. What does this polity apply to and who does it apply to?
This policy applies to all employees, contractors, consultants, managers, trainees, casual and agency workers.
It sets out what they should do if they have reason to believe that something dangerous, illegal or unethical is happening at work and that it affects (or threatens to affect) them or other colleagues.
When you report such concerns, it is called whistleblowing.
We are committed to the highest standards of integrity in everything we do.
However, all organizations may from time to time be affected by conduct that is dangerous, illegal, or in violation of ethical or professional codes.
Please follow the procedure in Part II of this policy and report any concerns about such behavior immediately so that we can take the necessary steps to address them as soon as possible.
This policy also applies to the conduct of third parties, such as suppliers, service providers and clients, as well as to our employees. If you have concerns about a third party, please contact us first before contacting anyone else. The contact person, Tomáš Hradil, will explain how to proceed.
We will always take your concerns seriously and they will be thoroughly investigated by the relevant staff. The most important thing is that you feel confident and can follow Part II with confidence. There is no risk of repression from those who point these concerns to us - we value all such announcements and respect those who make them to us. We all play an important role in ensuring that our company and all those who work in and with it act professionally, lawfully and appropriately.
2. It is not part of your employment contract.
This policy is not part of your employment contract. We, LIPOELASTIC a.s., can change these principles at any time.
3. What activities are usually considered relevant to whistleblowing?
This is not an exhaustive list, but the types of issues you may want to report to us through whistleblowing may include:
- Any activity that you suspect is a criminal offense
- Any activity that you suspect threatens health and safety
- Any activity that you suspect could harm the environment
- Any activity that you suspect involves bribery and corruption
- Any non-compliance with legal or regulatory obligations
- Any non-compliance with professional requirements
- Any attempt to conceal one or more of these activities
If you are unsure whether these principles apply to something you are afraid of, contact Tomáš Hradil.
Bullying or harassment
If your complaint concerns the conduct of others towards you, our Complaints Policy contains appropriate instructions on how to proceed (the Complaints Register, which has been in place in the company since 2017). These types of behavior are not covered by this notification policy.
4. Confidentiality and anonymity
We always encourage you to communicate your concerns openly and we do not actively recommend anonymous reporting. This is because it is not always easy to handle and investigate anonymous reports, especially since if we cannot ask you to clarify further details, we may have difficulty clarifying and finding evidence in support of your claims and / or drawing an informed conclusion. Under these circumstances, we run the risk of missing evidence or opportunities to gather important supporting information or identify useful witnesses, because we simply do not know of their existence despite all our efforts to expose them.
However, if you wish to keep your identity anonymous, we will do our utmost to ensure that your anonymity and confidentiality are maintained, if possible. If we have to disclose your identity to other people as part of the investigation, we will always discuss our wishes and the reasons why we wish to find out your identity in advance.
We will protect you from retaliation and you will find more information on how we do it and what your rights are in section 5 below.
5. We protect whistleblowers
There is no repression for mistakes, even if, after our investigation (which we always conduct thoroughly and conscientiously), we conclude that there has been no violation of the law, principles or unethical conduct. However, in order for a notification to be protected, it must, in the reasonable opinion of the person making the notification, demonstrate that one or more of the following events has occurred, is occurring or is likely to occur and that it is in the public interest to make the notification:
- A crime
- Failure to fulfill a legal obligation
- Judicial error
- Threats to the health and safety of persons
- Danger to the environment or
- Intentional concealment of any of the above facts
If at any time you feel that we have not treated you fairly or correctly in dealing with your whistleblowing, you must inform us immediately. You should first inform Tomáš Hradil, and if you are not satisfied with the outcome of this interview, you should follow the procedure set out in our Complaints Registry policy.
We also protect whistleblowers from others, so if the whistleblower notifies us that others have treated him or her inappropriately (including that he or she has been threatened as a result of his or her concerns), we will take disciplinary action against those individuals. The consequence of our action may be the dismissal of such person (s) for gross violation of work discipline. Notifiers may also have the right to take legal action against such persons.
You can contact a lawyer to find out more about your whistleblower rights and how you are entitled to protection.
6. Whistleblowing to other persons outside LIPOELASTIC a.s.
Our principles apply to the process of notifying, investigating and resolving errors at the workplace in LIPOELASTIC a.s.
The notification process, which we have carefully implemented, has been designed to ensure that we are able to address all concerns raised to the best of our ability and that we protect you in this process.
For these reasons, we assume that it will be very rare, if at all necessary, for you to involve someone outside LIPOELASTIC a.s. in this process.
However, we recognize that in exceptional cases, you may wish to involve an external body - such as an industry regulator - and / or a lawyer who may refer you to the appropriate regulatory body for the type of issue you wish to raise.
Print / media connection
The involvement of the media in whistleblowing often results in aggravation of the situation, not its support. It can make it significantly more difficult to gather evidence and the willingness of other relevant people to support the process.
We therefore strongly discourage you from involving the media. Unless exceptional circumstances arise, we will consider any contact with the press as a serious disciplinary issue that justifies dismissal. For example, we would generally expect that you have taken all reasonable steps to resolve the matter internally or with an external regulator and that you have fully consulted with a lawyer before you can justify the involvement of the press.
Part II: Our procedure for reporting suspected violations of the law
Follow these steps:
- Communicate your concerns first and foremost to the responsible person, Tomáš Hradil. You can do so in writing or in person.
- If you do not wish to discuss your concerns with Tomáš Hradil or you think that your concerns are extremely serious, you should contact Petr Remeš.
- Please explain that you are raising concerns about whistleblowing policies and procedures. Then provide all key facts, including the names of the people involved and all relevant data.
- You may be invited to a meeting where you can discuss your concerns. You can take someone with you to this meeting - and to all subsequent meetings. This companion can be your colleague. Everyone who accompanies you will be asked to agree to maintain the strict confidentiality of the content of the meeting, including any materials that will be communicated and / or reviewed during the meeting. This obligation of confidentiality applies to the period before, during and after the meeting and to any follow-up investigation we may conduct in connection with your concerns.
- After this meeting, we will investigate the issues raised and we may ask you to come to other meetings that will help us in our efforts. We may also choose to involve appropriate external (or internal) experts to help us conduct a thorough, fair and accountable investigation.
- Our relevant staff involved in this investigation will keep you informed of the progress of the investigation. For a number of reasons that relate generally to legal obligations, including the obligation to maintain confidentiality, to others or in connection with any legal advice we may choose to use on our own behalf, we will not be able to share all details of our findings or actions with you. However, we will always do our best to reassure you that we are taking your concerns seriously and conducting responsible investigations.
- It is possible that the result of the survey will not be satisfactory for you. If this happens, you have the right to complain to Petr Remeš and ask for a review of what has been done and closed.
If you have raised concerns in good faith, our process and all those involved in its implementation will support and protect you. However, if you raise a false concern with us in bad faith (eg for bad reasons), we will apply our disciplinary policies and disciplinary proceedings may be instituted against you.
Part III: Contacts
+420 571 116 300
WHISTLEBLOWING, Vrbenská 887, Valašské Meziříčí
Possibly mailbox located at the entrance of the building at Vrbenská 887, Valašské Meziříčí - mark the envelope "WHISTLEBLOWING"
Tomáš Hradil – [email protected]
Petr Remeš – [email protected]