I P C plast spol. s r.o., ID No.: 005 15 566, registered office at Palackého 753, 394 68 Žirovnice
(hereinafter referred to as the employer)

Article I.
Introductory provisions

1.1 With this directive (hereinafter referred to as the “internal directive”), the employer further regulates the rules concerning the protection of whistleblowers and the internal reporting system in accordance with Directive (EU) 2019/1937 of the European Parliament and of the Council (EU) 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Union law (hereinafter referred to as the “EU Directive”) and Act No. 171/2023 Coll., on the protection of whistleblowers (hereinafter referred to as the “Act”). The purpose of this internal management standard is to prevent certain unlawful conduct, to ensure the protection of whistleblowers reporting such unlawful conduct and certain other persons from retaliatory measures, and to ensure the effective functioning of the internal reporting system. This directive is valid within the company and regulates the procedures and rules that must also be applied to the conditions of subsidiaries.

1.2 The employer considers the policy of preventing unlawful conduct to be of fundamental importance, and it is therefore not only in its interest, but also in the interest of all its employees and other cooperating persons involved in the employer’s operations, that any suspicion of unlawful conduct or imminent unlawful conduct be reported in a safe manner, properly investigated, and, where appropriate, that adequate consequences are drawn and necessary measures are taken. The main objective of whistleblower protection is to enable the detection of possible illegal conduct in the employer’s workplaces.

1.3 Reporting suspected illegal activity is an employee’s right, not an obligation.

Article II.
Notifications and Notifiers

2.1 This internal directive applies to reports made to employers pursuant to Act No. 171/2023 Coll., on the protection of whistleblowers, with the exception of reports from whistleblowers who do not perform work or other similar activities for the employer pursuant to Section 2(3)(a), (b), h) or i), who are hereby excluded from receiving reports under this internal guideline (hereinafter referred to as “reports”). A report is a submission by a natural person containing information about possible unlawful conduct that has the characteristics of a criminal offense or misdemeanor or violates a legal regulation or European Union regulation, which the whistleblower learned about while performing work or other similar activities or in connection with work or other similar activities. The purpose of whistleblower protection is to take security measures that ensure their protection to the greatest extent possible, including protection of their identity and protection against retaliatory measures by the employer in the form of, for example, termination of employment or non-renewal of employment, transfer to another job, reduction of salary, etc. This protection cannot be provided to a person who intentionally and knowingly submits incorrect, false, or misleading information.

2.2 Anonymous reports shall only be considered valid once the identity of the reporting person has been revealed. Until then, the report shall only be recorded.

2.3 The employer shall publish comprehensive and comprehensible information on its website about which notifications are subject to regulation by law.

2.4. The employer excluded from the group of whistleblowers who are entitled to file reports persons who do not perform work or other similar activities for the employer.

2.5. Protected whistleblowers may include employees in employment relationships, job applicants, employees working under DPČ and DPP contracts, agency employees, volunteers, interns, and trainees.

2.6. The report must contain the name and surname of the reporter, date of birth, i.e. the identity of the reporter, otherwise the report will not be considered. Anonymous reports will be recorded by the employer but will not be further investigated. Anonymous reports will be investigated by the employer once the identity of the reporting person is revealed. From that moment on, the reporting person will also be protected from retaliatory measures.

A sample form for whistleblowers is available on the employer’s website: www.ipcplast.cz

2.7. Information about the identity of the whistleblower is not publicly available. The whistleblower shall disclose the identity of the persons concerned in the report for the purpose of assessing the merits of the report.

2.8.A whistleblower who reports unlawful conduct, even anonymously, must not be penalized, disadvantaged, or subjected to pressure in any way in connection with this conduct. This protection does not apply to reports that constitute the elements of the crime of defamation under Section 184 of the Criminal Code or that are knowingly false.

Article III.
Internal reporting system

3.1 According to the law, the employer is a so-called obligated entity and is therefore required to establish a so-called internal reporting system.

3.2 An internal reporting system is an internal information channel established by the employer for the purpose of submitting reports, using methods that are required by law and further specified in this internal directive (hereinafter referred to as the “internal reporting system”).

3.3 Whistleblowers are entitled to submit their reports:

a) electronically to a special e-mail address for receiving notifications

ipc.whislteblowing@seznam.cz
(hereinafter referred to as the “e-mail address”); only the relevant person has access to the e-mail. This secure Internet communication platform was set up by the employer.

b) or verbally, after agreement with the relevant person at the workplace on an agreed date on working days from Monday to Friday from 6:00 a.m. to 2:15 p.m. in office no. 2.03 at the HR department. A record will be made of the verbal notification, with the subsequent possibility of checking the transcript of the verbal notification, modifying it if necessary, and approving it with the signature of the notifier.

c) Written reports can be sent to I P C plast spol. s r.o., ID No.: 005 15 566, registered office at Palackého 753, 394 68 Žirovnice. Notifications must be submitted in a properly sealed envelope marked “WHISTLEBLOWING – TO THE ATTENTION OF THE RELEVANT PERSON – DO NOT OPEN.” Failure to comply with this condition may compromise the confidentiality of the whistleblower’s identity or the confidentiality of the information disclosed.

d) Reports may also be submitted to the employer in a box located at the HR office and the relevant person on working days from Monday to Friday between 6:00 a.m. and 2:15 p.m. at office no. 2.03 in the HR department. Notifications must be submitted in a properly sealed envelope marked “WHISTLEBLOWING – TO THE ATTENTION OF THE RELEVANT PERSON – DO NOT OPEN.” Failure to comply with this condition may compromise the confidentiality of the whistleblower’s identity or the confidentiality of the information disclosed.

e) Reports may also be submitted to an external investigator, the Ministry of Justice of the Czech Republic, in writing: Ministry of Justice of the Czech Republic, Vyšehradská 16, Prague 2, Postal Code 128 10, or by email: oznamovatel@msp.justice.cz or by telephone: 00420 221 997 840.

Article IV.
Retaliatory measures

4.1.Retaliatory measures are understood to mean actions or omissions in connection with the work or other similar activities of the whistleblower, which were caused by the reporting and may cause harm to the whistleblower or a person close to them. Retaliatory measures should have at least a potential impact on the work or other activity of the whistleblower. There is a clear causal link between the report and the retaliatory measures.

4.2. The following are considered retaliatory measures in particular:

a) termination of employment or non-renewal of fixed-term employment
b) termination of a legal relationship established by an agreement on the performance of work or an agreement on work activity
c) dismissal from a managerial position
d) imposition of disciplinary measures or disciplinary punishment
e) reduction of wages, salary, or remuneration
f) transfer or reassignment to other work
g) performance review
h) denial of professional development opportunities
g) change in working hours
i) requirement for a medical examination or occupational health examination
k) interference with the right to protection of personality

4.3. Whistleblowers and persons related to whistleblowers are protected against retaliatory measures.

Article V.
Competent person

5.1 The designated person is Mgr. Blanka Brychtová, and the HR manager is Ing. Marie Vaňásková. (hereinafter referred to as the “designated person” or “designated persons”).

5.2 Where this internal directive uses the term “relevant person,” this also refers to all relevant persons designated by the employer, if more than one has been designated.

5.3 In particular, the relevant person:
a) receives, records, and assesses the validity of reports submitted through the internal reporting system; if valid, subsequently investigates the received report of a breach of legal obligations;

b) proposes corrective measures or measures to prevent an unlawful situation in connection with the report submitted, unless this procedure could lead to the disclosure of the identity of the whistleblower or other persons who may not be subjected to retaliatory measures under the law;

c) maintain confidentiality regarding facts learned in the course of performing their duties under the law, even after the termination of such duties, unless otherwise provided by law;

d) acts impartially and objectively in the performance of its activities in accordance with the law.

5.4 The relevant person is obliged to ensure that the confidentiality of information concerning the identity of the whistleblower and the content of their report is maintained, in particular vis-à-vis the employer, its employees, and third parties. In their report, the whistleblower gives their consent for the content of the report to be disclosed for the purposes of assessing the validity of the report and its subsequent investigation only to designated competent persons, affected persons, and persons involved in the investigation of the report.

5.5 Zaměstnavatel je povinen na svých webových stránkách uveřejnit jméno a příjmení příslušné osoby, její telefonní číslo a e-mailovou adresu pro doručování.

Article VI.
Responsibilities and Powers

6.1 The statutory body of the company is responsible for ensuring the creation of an internal reporting system, including the proper maintenance of documentation and protection of data related to reporting. It is also responsible for appointing the relevant person.

Article VII.
What can be reported under the law

7.1 The whistleblower has the right to use the internal reporting system to report unlawful conduct that they have become aware of in the course of their work or other similar activities, or in connection with their work or other similar activities, and which meets at least one of the following criteria:

a) It has the characteristics of a criminal offense
b) It has the characteristics of an offense for which the law stipulates a fine with an upper limit of at least CZK 100,000
c) It violates the Whistleblower Protection Act
d) It violates another legal regulation or European Union regulation in the area of

1. financial services, statutory audit and other assurance services, financial products and financial markets

2. corporate income tax

3. preventing money laundering and terrorist financing

4. consumer protection

5. compliance with product requirements, including safety requirements

6. safety of transport, transportation, and operation on roads

7. Environmental protection

8. Food and feed safety and animal protection and health

9. Radiation protection and nuclear safety

10. economic 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

14. functioning of the internal market, including protection of competition and state aid under European Union law.

Article VIII.
Procedure for handling notifications

8.1 Once the relevant person has received a report from the whistleblower by any means provided for in this internal policy, they are obliged to notify the whistleblower without undue delay, but no later than seven days from the date of receipt of the report, unless:
a) the whistleblower has expressly requested the relevant person not to notify them of the receipt of the report;
b) it is clear that notification of receipt of the report would reveal the identity of the reporting person.

8.2 The competent person is obliged to assess the validity of the notification and, if the notification is found to be valid, the competent person shall notify the notifier in writing within thirty days of receipt of the notification. In cases that are factually or legally complex, this period may be extended by up to thirty days, but no more than twice. The competent person shall notify the reporting person in writing of the extension and the reasons for it before the deadline expires, unless: a) the reporting person has expressly requested the competent person not to notify them of the extension of the above deadline and the reasons for it;
b) it is clear that notification of the extension of the above-mentioned deadline and the reasons for its extension would reveal the identity of the notifier.

8.3 If, when assessing the merits of the report, the relevant person finds that it is not a report under the law, they shall notify the reporter thereof without undue delay.

8.4 If the report is assessed as justified, the relevant person shall propose measures to the employer to prevent or remedy the unlawful situation. If the employer takes any measures in response to this proposal, the relevant person shall notify the whistleblower without undue delay, unless: a) the whistleblower has expressly requested the relevant person not to notify him or her of the measures taken;
b) or it is clear that notification of the measures taken would reveal the identity of the whistleblower.

8.5 If the report is not assessed as justified, the relevant person shall inform the reporter without undue delay that, based on the facts stated in the report and all circumstances known to them, they have not found any suspicion of unlawful conduct, or they have found that the report is based on false information, and shall inform the reporting person of their right to file a report with a public authority.

8.6 Any notification to the whistleblower under this section shall be made by the relevant person in writing to the address of residence or e-mail address provided by the whistleblower in connection with the report, or to the address or e-mail address available to the relevant person.

Article IX.
Procedure for Evaluating Notifications

9.1 In order to assess the validity of the report, the competent person is obliged to conduct a thorough investigation to the extent necessary for a final decision on how to proceed with the report within the assessment. The competent person shall first assess the admissibility of the report. A report is admissible if it has been submitted by a person who is considered a whistleblower under the Whistleblower Protection Act and this Directive. Furthermore, the report must contain basic information about the identity of the whistleblower and a description of the unlawful conduct. If the report is admissible, an investigation into the matter will be initiated. Reports assessed as inadmissible, which cannot be remedied even by questioning the whistleblower, will be assessed as deferred. Such reports will be recorded and will not be investigated. The competent person will immediately inform the whistleblower of any deferred reports.

9.2 The relevant person is entitled to request any data and information from the employer and its employees as part of the investigation, as well as paper, electronic, and other documents, to make copies of them, and to use any other procedures and means that do not conflict with legal regulations and are appropriate to the nature of the investigation. The employer and its employees are obliged to provide the competent person with all cooperation in this regard. The facts stated in the report are verified by means of an internal investigation. The reporter may be asked to clarify the information provided or to provide additional information. During the investigation, partial measures may be taken to prevent the continuation of illegal activities.

9.3 The employer and its employees are obliged to refrain from any independent investigation of information regarding who is being investigated by the relevant person and who may be a potential whistleblower.

9.4 The employer and its employees are obliged to maintain confidentiality regarding their cooperation with the relevant person.

9.5. The relevant person shall prepare a final report at the end of the investigation.

Article X.
Procedure for proposing measures

10.1 If the report is assessed as justified, the relevant person is obliged to submit to the employer, within thirty days of the date of completion of the assessment of the justification of the report, a written proposal for measures to prevent or remedy the unlawful situation (hereinafter referred to as the “proposal”).

10.2 The proposal must contain specific measures and must be duly justified.

10.3 The employer is not bound by this proposal in any way and it is solely at its discretion whether to comply with it in full or in part, or to reject it in full or in part. If the employer does not accept the measures proposed by the relevant person, it shall take other appropriate measures to prevent or remedy the unlawful situation. However, it must notify the relevant person who submitted the proposal of these facts no later than thirty days from the date on which the proposal was submitted.

Article XI.
Education and information on whistleblower protection

11.1 The employer undertakes to inform and ensure the training of its employees, particularly in the area of whistleblower protection, regarding their right to report under the law and their obligation to cooperate with the relevant person.

11.2 The employer undertakes to inform all potential whistleblowers in an exhaustive and comprehensible manner, particularly on its website, about their right to report, the various methods of reporting under this internal policy, and all their rights and obligations under the law.

Article XII.
Records of notifications

12.1. Records of notifications are kept to the extent of:

• date of receipt of the notification;
• name(s), surname, date of birth, and contact address of the notifier, if known to the relevant person;
• a summary of the content of the report and the identification of the person against whom the report was made, if their identity is known;
• the date of completion of the assessment of the merits of the notification by the competent person and its outcome.

12.2. The relevant person is obliged to retain reports submitted through the internal reporting system for a period of five years from the date of receipt (hereinafter referred to as “retained reports”).

12.3. Only the relevant person has access to the notification records and stored notifications. The employer shall ensure their security in order to prevent access by persons other than those authorized.

This internal directive shall take effect on August 1, 2023.