Whistleblowing

Whistleblowing

In accordance with Act No. 171/2023 Coll., on the protection of whistleblowers, as amended, Havlíkova přírodní apotéka s.r.o. (hereinafter referred to as the "Company") has set up an internal whistleblowing system for the submission of information about possible violations.

Who report?

A whistleblower is anyone who performs or has performed work or similar activities, even indirectly, for the Company - employees, contractors, trainees, job applicants. Notification can also be made anonymously.

What is reported?

Information is reported about a possible violation that has occurred, is occurring or is about to occur and which:

(a) has the characteristics of a criminal offence

(b) has the characteristics of an offence with a threshold of at least CZK 100 000

(c) violates the law

(d) infringes any other EU law or regulation in the following areas:

1. financial services, statutory audit and other assurance services, financial products and financial markets,
2. corporate income tax,
3. prevention of money laundering and terrorist financing,
4. consumer protection,
5. compliance with product requirements, including product safety,
6. transport, transport and road safety,
7. protection of the environment,
8. food and feed safety and the protection of animals and their health,
9. radiation protection and nuclear safety,
10. 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. the protection of the financial interests of the European Union, or
14. the functioning of the internal market, including the protection of competition and State aid under European Union law.

The notification contains the name, surname and date of birth, or other information from which the identity of the notifier can be inferred; the identity of the notifier shall be presumed to be true.

Instructions on false notification

A natural person who has made a false report shall not be protected from reprisals. The whistleblower commits an offence with a fine of up to CZK 50 000.

Form of notification

A notification may be made by:

1. Writing.

 

- By sending an e-mail to whistleblowing@havlikovaapoteka.cz

- By sending a letter in paper form to U Nesypky 2a, Prague 5, 150 00 marked "Do not open - Whistleblowing".

 

2. Orally

 

By telephone at +420 774 805 305 - telephone conversations are not recorded.

 

3. In person

A date for a face-to-face meeting with the person concerned will be arranged within 14 days of receipt of the request for a meeting (by email, telephone).

An audio recording or a written record will be made of the oral notification, and the audio recording may only be made with the consent of the notifier. In the case of a personal notification, a written record shall be made.

4. In addition, notification may be made to the Ministry of Justice or public authorities.

 

Time limit for processing the notification

The notifier must be informed within 7 days of receipt of a notification submitted via the internal notification system, either verbally by telephone or in writing. If the notifier requests a personal notification, this must be received within 14 days of the date on which the notifier requested it.

Furthermore, the competent person shall assess the validity of the notification and inform the notifier in writing of the results within 30 days of the date of receipt of the notification.

 The time limit may be extended twice for a further 30 days. The competent person shall inform the notifier in writing of the extension and the reasons for the extension.

If the notification is justified, the competent person shall propose measures to the Company.

Notifications shall be kept for a period of 5 years after receipt of the notification.

Protection of the notifier

The purpose of the protection is to take measures to ensure the protection of the whistleblower, to protect his/her identity, and to protect him/her against retaliatory measures by the Company (termination of contract, termination of employment, reduction of salary, disciplinary measures, denial of professional development, etc.). Protection also applies to persons close to the whistleblower, persons providing assistance in finding out information, colleagues at work, etc.

The person concerned

A competent person is a natural person of good character who receives a notification from a whistleblower. The tasks of the competent person include:

(a) receiving and assessing the validity of notifications made through the internal notification system,

(b) propose to the obliged entity measures to remedy or prevent an unlawful situation following a notification, unless such action could reveal the identity of the notifier or the person,

(c) carry out the instructions of the obliged entity, unless they jeopardise or obstruct the performance of its activities,

(d) act impartially in the performance of its activities under this Act,

(e) shall maintain confidentiality of the facts of which it has become aware in the performance of its activities under this Act, even after the performance of those activities has ceased, unless otherwise provided by law.

The competent person shall not be penalised for the proper exercise of his activities under this Act.

The competent person in the Company is the Office Manager, +420 774 805 305.