Whistleblowing
Within the meaning of the Czech Act on the Protection of Whistleblowers (“the Act”), EmbedIT s.r.o. (“EmbedIT”) has established the following internal reporting system for whistleblowers and appointed the persons set out below who are responsible for receiving and dealing with the notifications ("Nominated Persons”).
Who can report?
Whistleblowers can be persons who are employees of Embed IT, or execute similar activity for Embed IT, including members of corporate bodies, job applicants, trainees, or former employees. According to Section 2(3)(b) of the Act, submission of notification by persons exercising rights and obligations from a contract for the provision of supplies, services, construction works, or other minor performances are excluded.
What can be reported?
Notifications may relate to illegal conduct of which the whistleblower became aware in connection with the performance of his/her EmbedIT and which:
- has elements of a criminal offence,
- has elements of administrative offense for which the law stipulates a fine of at least CZK 100,000,
- violates the Act itself, or
- violates EU law in the areas specified in the Act (e.g. the areas of public procurement, consumer protection, preventing the legalization of proceeds from criminal activity and terrorist financing, or environmental protection).
How to report and to whom?
Whistleblowing notice can be given:
- to email: CZwhistleblowing@homecredit.eu
- by phone: +420 602 777 425
- during personal appointment (upon agreement with a Nominated Person)
- in writing to Home Credit International a.s., Evropská 17, 160 00 Prague, attn. Pavel Procházka
- through the relevant department of the Ministry of Justice
Nominated Persons include:
- Martin Šeda, Group Chief Legal & Compliance Officer,
- Pavel Procházka, Head of Compliance, and
- Hana Panušková, Senior Compliance Specialist.
Protection
Whistleblowers are afforded the protection of identity and the protection from retaliatory actions. Protection under the Act is not provided to whistleblowers who make knowingly false statements and to anonymous whistleblowers until their identity is known.
If I am employee of Czech EmbedIT but want to report other issues
Persons who are employees (or similar position) of Embed IT and want to report issues not falling within the regulatorily-prescribed scope described above may use the email etickalinka@homecredit.eu or report to PPF FH Group via (i) personal notification to a staff of PPF FH Group Legal Department, or (ii) web interface at etickalinka.ppf.eu. These issues may be, for example, breach of ethical rules or violation of internal rules and procedures of lesser intensity or impact.
If I am not employee of EmbedIT
Persons who are not employees (or similar position) of EmbedIT, i.e. third parties or employees of other Home Credit companies, can make whistleblowing report under the local Whistleblowing channels or to etickalinka@homecredit.eu.