Helios indoor announcement system

INTERNAL NOTIFICATION SYSTEM

Act No. 171/2023 Coll. on Whistleblower Protection

Annexes of an evidential nature

1. registration table
2. unauthorised notification
3. acknowledgement of receipt of notification
4. record of the oral notification

INTERNAL NOTIFICATION SYSTEM

Hotel Helios, s.r.o., ID No.: 27742776, with registered office at Křenová 299/26, Brno 602 00, registered in the Commercial Register maintained by the Regional Court in Brno, Section C, Insert 55958.

(hereinafter referred to as the “Company“)

In accordance with Act No. 171/2023 Coll., on Whistleblower Protection (the “Act“), which transposed into Czech law Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report infringements of Union law (the “Directive“), the Company’s principles of conduct and the applied whistleblowing and whistleblower protection policy, the Company informs of the following:

1. 
   SETTING UP AN INTERNAL NOTIFICATION SYSTEM

The Company has established an internal reporting system (“IRS“) for the purpose of reporting conduct in which an individual, as a whistleblower, is perceived to have violated the employer’s obligations specified below.

1. 
   DEFINED AREAS

The VOS is designed for reporting such violations that:

1. has the elements of a crime,
2. has the characteristics of a misdemeanour for which the law sets the rate of a fine, the upper limit of which is at least CZK 100,000,
3. violates this Act, or
4. infringes any other legislation or regulation of the European Union in the field of:

1. financial services, due diligence 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, traffic and road safety,
7. environmental protection,
8. food and feed safety and animal 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.

III.
ANNOUNCER

A whistleblower who may use the company’s VOS to make a notification is a natural person who makes a notification in the context of his or her employment relationship, is self-employed, a partner, a person in a statutory, management or supervisory body, a volunteer, an intern or a person carrying out activities under a contract for the provision of supplies, services, construction work or other similar contract.

III.
METHOD OF NOTIFICATION

The notifier should have reasonable grounds for believing that the information notified about the infringement is true at the time of notification. Therefore, knowingly false facts cannot be notified.

Notification via VOS can be made:

• by e-mail to whistleblowing@heliosjeseniky.cz, which is set up exclusively to receive notifications;
• by telephone, via the telephone line +420 737160594, +420 608866358 (a written record of the call is made) during normal working hours;
• in writing by letter sent to the address of the company’s registered office Hotel Helios, Křenová 299/26, Brno 602 00, directly to the hands of the competent person Bc. Marie Nezvalová; for the purpose of maintaining confidence in this method of notification, the addressee will be marked on the document as follows:

Competent person in charge – DO NOT OPEN (only to the competent person)
company
registered office

• in person at the company’s registered office with the authorized person, Leona Vejberová, at any time during normal business hours, preferably by prior telephone or e-mail to the above-mentioned contacts; if the notification is made in person, a report must be drawn up, and an audio or visual recording of such notification may be made with the consent of the notifier;
• via the external notification system set up by the Ministry of Justice: https://oznamovatel.justice.cz/chci-podat-oznameni/

In the notification, the notifier shall provide personal data from which the identity of the notifier can be inferred.

The notification can be made anonymously, but this form of notification does not protect the whistleblower from retaliation.

The competent person shall acknowledge receipt of the notification in writing to the notifier within 7 days from the date of receipt of the notification, and the results of the assessment shall be communicated to the notifier by the competent person within 30 days from the date of receipt of the notification, which may be extended for up to a further 30 days in factually or legally complex cases, but not more than twice. The reasonableness and truthfulness of each notification shall be assessed and, if the notification is reasonable and truthful, corrective measures shall be taken.

Knowingly making a false report that is intended to harm the company may be sanctioned.

The competent persons designated by Hotel Helios s.r.o. under the Whistleblower Protection Act are:

• Bc. Marie Nezvalová, manager of Helios Resort, mobile: +420 608 866 358
• Leona Vejberova, Director of Helios Resort, mobile: +420 737 160 594

1. 
   WHISTLEBLOWER PROTECTION

A whistleblower who has made a notification through a VOS is protected from any retaliatory measures that may be applied against it. This protection also extends to other persons to whom it is due under the law, i.e. persons who are close to the whistleblower, persons who have facilitated or enabled the notification or persons who have a professional relationship with the whistleblower. The identity of the whistleblower shall also be protected.

V.
PROCESSING OF PERSONAL DATA

Personal data is processed in accordance with the general data protection legislation. The notifier expressly consents to the processing of the personal data communicated by him/her when making the relevant notification. The notifier acknowledges that the data communicated at the same time as the notification are subject to a registration obligation which lasts for a period of 5 years from the date of receipt of the notification.

Effective from 1.10. 2023

In Brno on 20.9.2023

EVIDENCE SHEET

Notification of unauthorised notification

Dear Sir/Madam,

I hereby acknowledge receipt of your notification dated ……….. regarding …………………………………….

According to a preliminary assessment of your notification, made via the company’s internal notification system …………….., I inform you that the infringement you have notified does not concern any of the defined areas.

In view of the above, I hereby suspend further investigation of your notification.

V……………….days……………..

…………………………………..
signature of the person concerned

• this text can also be used in the case of notifications made by email

Acknowledgement of receipt of notification

Dear Sir/Madam,

I hereby acknowledge receipt of your notification dated ……….. regarding …………………………………….

I inform you that the validity of your notification is currently being assessed and you will be informed of the outcome of the assessment within 30 days. In the event that your notification is considered to be factually or legally complex, this period may be extended by up to two additional 30 days.

V……………….days……………..

…………………………………..
signature of the person concerned

• this text can also be used in the case of notifications made by email

RECORD OF THE ORAL NOTIFICATION

Date of receipt of notification:

Acceptance of the notification by the competent person: details of the competent person

Personal data of the notifier:

Consent to the making of a visual and/or audio recording: YES NO signature ……………

Announcement:

Signature of the competent person who received the notification: …………………………