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Whistleblowing Notice

This page allows a whistleblower to inform KOMERČNÍ POJIŠŤOVNA, a. s. of facts of which he/she has become aware directly or indirectly in the course of his/her work or other similar activity and which are in breach of the law, internal regulations or ethical principles, or which he/she has been the target of improper conduct (hereinafter referred to as "Whistleblowing"). Persons who do not fall under the above definition of a whistleblower may also make a Whistleblowing.

How do I send a Notice?

This Notice can be made:
  1. In writing:

    At the Company's address to the attention of the Competent Person
    Komerční pojišťovna, a.s.
    Nám. Junkových 2772/1
    Prague 5 155 00
    indicate "Whistleblowing - DO NOT OPEN" on the envelope

    To the designated email: whistleblowing@komercpoj.cz

    Through the internal whistleblowing system WhistleB

  2. By telephone - to the contacts of the Competent Persons indicated
  3. At a personal meeting – the date will be arranged with the Competent Person within 14 days of sending the Notice.

Who should I send the notification to?

The following persons have been designated to receive the notification:
  • JUDr. Peter Vrábel, Director of Legal, Compliance and Internal Control, tel.: 725 826 315
  • Bc. Jan Ettl, Senior Compliance Specialist, tel.: 724 372 448

(collectively referred to as "Competent Persons" or "Competent Person")

Common email address for receipt of Notices: whistleblowing@komercpoj.cz

For purposes of further communication, please include your name, surname, date of birth or other identifying information in the Notice.

Notification may also be made anonymously.

What is the next course of action?

The whistleblower will receive a written acknowledgement of receipt of the Notification, no later than 3 working days from the date of receipt. At the same time, the whistleblower will be informed whether, or not his/her report falls within the definition of a report under Act No. 171/2023 Coll., on the protection of whistleblowers ("ZoOO") and what rights and obligations he/she is entitled to in this process. The information provided will be treated as strictly confidential.

The competent person will proceed with the investigation in such a way that the identity of the whistleblower is not disclosed. Throughout the investigation, the identity of the whistleblower will be known only to the Competent Persons. In the event, that it is not possible to proceed with the investigation without disclosing the identity of the whistleblower to others, the Competent Person will inform the whistleblower of this and seek his/her explicit consent to this procedure.

This does not apply in cases where the identity of the whistleblower is requested by public authorities. However, the competent person must inform the whistleblower in advance, together with the reasons for which it is obliged to provide the identity information and give the whistleblower the opportunity to comment on the provision of the information.

The investigation will then assess the reasonableness of the Notification and other relevant facts. The competent person will then inform the whistleblower in writing of the results of this assessment within 30 days of receipt of the Notification. Where the matter is factually or legally complex, the Competent Person may extend this period by 30 days, up to a maximum of twice. In such cases, the Competent Person must always inform the whistleblower of the extension and the specific reasons for it.

If  the whistleblower is eligible for the status of whistleblower provided by applicable law, he will be protected from any retaliation, discriminatory measures, sanctions or dismissal (see Section 4 of the ZoOO). Otherwise, he is entitled to adequate compensation if he has suffered non-pecuniary damage as a result of the retaliatory measure. The whistleblower's waiver of the right to protection against retaliation shall not be taken into account.

If the legal requirements are not met, the whistleblower will not, by law, be eligible for whistleblower status or for the appropriate protection regime. However, reporting in good faith will not result in retaliation, even if he does not meet the applicable legal requirements for whistleblower status.

Furthermore, any report must be made in a responsible, non-defamatory and non-abusive manner. Failure to do so may result in (i) penalties, potentially of a criminal nature, for slander or defamation, in particular, and (ii) possible disciplinary proceedings.

If the Notification meets the definition under Section 2(1) of the ZoOO , the whistleblower will be subject to the protections provided by this Act. In such a case, the Notification may also be made through the external notification system established by the Ministry of Justice. This does not apply in the case of facts that fall under the scope of Act No. 253/2008 Coll., on certain measures against the legalization of proceeds of crime and terrorist financing, where the competent authority for dealing with the notification is the Financial Analysis Office.

In case your report or enquiry relates to another area, please contact the KB Pojišt'ovna Contact Centre.

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