Information for whistleblowers

With this document, the company informs whistleblowers of the manner and procedure by which they can forward notifications, identifies the relevant persons and specifies the basic rules regarding the handling of notifications.

Company name Langmeier & Co., advokátní kancelář s.r.o., ID number: 028 70 355, with registered office at Na bélidle 997/15, Smíchov, 150 00 Prague 5, registered in the commercial register maintained by the Municipal Court in Prague under file no. stamp C 224324 („Company“).

What is whistleblower protection?

Whistleblower protection is governed by Act No. 171/2023 Coll., on the Protection of Whistleblowers, as amended („ZOO“). The main purpose of this law is to protect whistleblowers in the workplace from retaliation by employers.

Who can be a whistleblower?

A whistleblower, who is protected by the law, can be any natural person who comes across a possible illegal act at their workplace and decides to report it.

The notifier can be:

• employee,
• a person in a service relationship,
• former employee,
• job applicant,
• persons working on the basis of agreements on work carried out outside the employment relationship,
• a person working for the Company on the basis of self-employment (self-employed),
• temporarily assigned person,
• intern, volunteer,
• persons performing the function of a member of the Company's body,
• a person exercising rights associated with participation in the Company,
• suppliers, providers of services, construction works or other similar services.

What can be reported?

Information about a possible illegal act that has occurred or is expected to occur at the Company and which

• has signs of a crime,
• has signs of committing an offense for which the legal regulation stipulates the rate of the fine, the upper limit of which is at least CZK 100,000,
• violates the Whistleblower Protection Act itself,
• violates another legal regulation or regulation of the European Union in the area of:
  • financial services, statutory audit and other verification services, financial products and financial markets,
  • corporate income taxes,
  • preventing the legalization of proceeds from criminal activity and the financing of terrorism,
  • consumer protection,
  • compliance with product requirements, including their safety,
  • traffic safety, transport and road traffic,
  • environmental protection,
  • food and feed safety and protection of animals and their health,
  • radiation protection and nuclear safety,
  • economic competition, public auctions and public procurement,
  • protection of internal order and security, life and health,
  • protection of personal data, privacy and security of electronic communications networks and information systems,
  • protection of the financial interests of the European Union, or
  • the functioning of the internal market, including the protection of economic competition and state aid according to European Union law.

Information excluded from reporting

In this way, the whistleblower may not report information that could break the obligation of confidentiality arising from other legal regulations. E.g. the duty of confidentiality of lawyers, legal assistants and lawyers' employees. Furthermore, also the obligation of confidentiality in the provision of health services, or the protection of information, the disclosure of which could clearly endanger ongoing criminal proceedings or the protection of special facts according to the law regulating crisis management and the AML law.

The law further prohibits the reporting of any information related to national security and security interests, sovereignty, territorial integrity, violation of the rules for awarding public contracts involving defense or security aspects, activities of intelligence services and other information listed in § 3, paragraph 3 of the ZOO.

If such information is part of the notification, the relevant person will not deal with such notification (or part of the notification) and will reject it or partially reject it without undue delay to the extent of this information excluded from notification.

How to make a notification?

Mgr. is authorized by the Company to receive notifications. Dominik Hoda

You can submit a notification:

• in writing to the email address: whistleblowing@langmeier.cz
• by phone at phone number: +420 722 231 566
• in person, after prior agreement with the authorized person. Personal notice will be provided to you within a reasonable time after your request, but no later than 14 days after your request.

Reports can be submitted anonymously, however, for faster and more efficient processing, your identification may be useful. Your personal information will be safe; only an authorized employee will have access to your identity and this information will not be shared with third parties without your express consent.

What should your announcement contain?

Please include in the notification:

• your name, surname and date of birth or other identification data (if you submit the notification anonymously, this is not necessary),
• details leading to suspicion of past or future violations of the rules, including specific reasons why you consider the conduct to be illegal,
• a statement as to whether you wish to be informed of the receipt of your notification and of the following measures and steps (in the absence of such a statement, we will provide you with information automatically),
• contact details for the delivery of relevant information (if you do not specify any special contacts, we will contact you via the email address from which the notification was sent, or as agreed).

How is your notification being processed?

After your notification, the authorized person will contact you within 7 days and confirm receipt of the notification. You will receive this confirmation either to the specified contact details or to the email from which the notification was submitted. In case we do not have your contacts, or if you do not wish to be informed, we will not send any confirmation. Information will also be omitted if it would lead to the disclosure of the identity of a third party.

Subsequently, an evaluation of the reasonableness of your notification will take place. Within 30 days of its receipt, the relevant person will investigate the circumstances and collect the necessary information. Depending on the results of the investigation, this person will inform you of:

• a possible extension of the deadline by another 30 days (maximum twice) in the case of a complex case,
• finding that your notification is reasonable,
• finding that your report is unfounded, with the possibility of submitting a report to a public authority,
• the fact that it is not a notification in accordance with the law.

If your notice is found to be reasonable, the authorized person will inform the Company of the proposed corrective measures. The law protects you, so the Company may not take any retaliatory action against you or anyone who helped you make a report.

Alternative ways to report and the duty of confidentiality under the AML Act

In addition to the internal reporting system, ZOO also provides other options for reporting. Unlike the internal system, the Company in these cases cannot ensure an immediate response and quick resolution of the situation. Among these external methods are:

• Notification via the notification system of the Ministry of Justice, which is available at the following address: https://oznamovatel.justice.cz/. In such a case, the notification will be handled exclusively by the Ministry of Justice.
• Public announcement, for example through the media, which is only possible under the conditions specified in § 7 paragraph 1 letter c) ZOO:
  • The company or the Ministry of Justice did not take appropriate measures within the set deadlines, in particular the relevant person did not assess the validity of the notification,
  • you have reason to believe that the actions described in the notification may lead to an immediate or obvious threat to internal order or security, life or health, the environment or other public interest, or to irreparable harm.
  • If your notification concerns information that is subject to the obligation of confidentiality according to Act No. 253/2008 Coll. on certain measures against the legalization of proceeds from criminal activity and the financing of terrorism (the so-called AML Act), then it is forbidden to report such information to the Ministry of Justice or otherwise publish it. In such a case, you can contact the Czech Bar Association or the Financial Analysis Office.