Internal Regulations
of the company Oční studio Aleš Žejdl s.r.o., Havlíčkova 837, 664 42 Modřice, ID No.:
26918773, registered in the Commercial Register maintained by the KS Brno under Rg. C 45042 (hereinafter referred to as the Company)

On whistleblower protection

I.

  1. The purpose of this internal regulation on whistleblower protection (hereinafter referred to as the “Directive”) is to establish the conditions for the submission of notifications of unlawful activities exclusively for persons who perform work or similar activities for the Company, as well as for the receipt and assessment of such notifications, as well as for the provision of remedies and the recording of the resolution of notifications, all in accordance with Act No. 171/2023 Coll., on whistleblower protection, as amended. The Directive is binding on all employees of the Company.
  2. Employees of the Company, including employees temporarily assigned to work for the Company, members of the Company’s bodies, other persons performing activities for the Company and any other natural and legal persons cooperating with the Company on the basis of a contractual relationship, are entitled to report a reasonable suspicion of a violation of the Company’s internal rules, the fulfillment of the elements of a criminal offence or misdemeanour on the part of the Company or its employees, statutory bodies or cooperating persons which they have discovered while performing work for the Company (hereinafter referred to as a Report). Where the Guidelines refer to a Whistleblower, persons related to the Whistleblower shall be deemed to be a Whistleblower. 
  3. The Whistleblower shall not be subject to any retaliation as a result of making a Notification and in connection with the performance of his or her job (without prejudice to the Company’s ability to take lawful action against the Whistleblower if he or she knowingly made a false Notification). Retaliation includes any action prompted by a Notification and taken by the Company or by another person at the Company’s direction that occurs in connection with the performance of the Whistleblower’s employment activities and that the Whistleblower may reasonably consider to interfere with his or her rights or legitimate interests, including, but not limited to, termination of employment, removal of a manager from a position, change in hours or work location, reduction in salary or compensation under the Agreement, unequal treatment or other disadvantage. 

II.

  1. Notification can be made via:
    a. Email: kozak@ocnistudio.cz;
    b. By post to the address: Oční studio Aleš Žejdl, s.r.o., Havlíčkova 837, 664 42
    Modřice, with the text: to the hands of Mgr. Jiří Kozák — do not open’;
    c. Via the telephone line 724 219 181;
    d. In person, by prior written or telephone appointment with an authorised person 
  2. Notifications are received exclusively by the person in charge, who is designated as Mgr. Jiří Kozák (hereinafter referred to as the Authorised Person), while in the event of absence or suspected conflict of interest, the representative, who is Bc. Zuzana Jagrová, (the representative is considered in this case to be the Authorised Person). 
  3. The Company and the Trustee will not accept anonymous communications where such anonymous information is not considered a Communication for the purposes of this Directive. However, this does not prevent the Company from verifying the validity and veracity of the information and taking any corrective action. 
  4. In addition to identifying the whistleblower, the notification should include:
    a. a description of the suspected violation;
    b. information about the violation, including a description of the violation, the time of the violation, and identification of the persons involved;
    c. information about the whistleblower and the persons involved (name, last name, date of birth and residence, position in the Company or relationship to the Company, telephone, email, relationship of the persons involved to the violation);
    d. Evidence and other available information and documents about the violation;
    e. The Whistleblower’s consent, if any, to inform the relevant administrative,
    police or other public authority. 

III.

  1. Only a person of good character as defined by law may act as a trustee.
  2. The person in charge shall ensure that the identity of the whistleblower is not disclosed without his or her consent, unless otherwise provided by law.
  3. The Entrusted Person shall maintain confidentiality of the facts that he/​she has learned in the performance of his/​her activities under this Directive, in particular the information contained in the Notification, even after the termination of the performance of such activities, and shall be entitled to use such information only for the purposes of the performance of the activities of the Entrusted Person.
  4. The Notification Officer shall consider the Notification in person and shall not be bound by the instructions of other persons in the Company if such instructions would tend to frustrate the purpose of the role of the Notification Officer.
  5. The Notification Officer shall act impartially in the exercise of the rights and obligations under the Guidelines.
  6. The authorised person shall not be penalised in any way for the proper performance of his/​her activities under the Directive and shall not be subject to any retaliatory measures.

IV.

  1. If possible, the Mandated Person shall instruct the whistleblower upon receipt of the Notice to protect his or her identity, the confidentiality of the information in the Notice, and the further procedure for dealing with the allegations in the Notice.
  2. The person in charge shall assess the reasonableness of the Notification within 30 days of its receipt. In factually or legally complex cases, this period may be extended by up to 30 days, but not more than twice. In such cases, however, the Notifier must always be informed of the extension and the reasons for it before the expiry of the previous period. 
  3. The Company shall ensure that the Authorised Person is provided with all necessary assistance for the assessment of the Notification.
  4. On the basis of the assessment of the Notification, the Authorised Person shall make a conclusion as to whether or not a breach of the Rules has occurred, whether the Notification was made in good faith by the Notifier believing in good faith that the information contained in the Notification is true, what the circumstances of the breach of the Rules were, and support such conclusions with available evidence.
  5. If the Authorised Person concludes that a breach of the Rules has occurred, he/​she shall notify the members of the Company’s statutory body, except for such members who are directly affected by the breach of the Rules, or, if the breach of the Rules affects all members of the Company’s statutory body, he/​she shall notify the members of the Company’s highest body, together with any proposed remedial action. 
  6. The person responsible shall further inform the whistleblower whether or not the Notification has been considered to be justified, unless the whistleblower has expressed a wish not to receive the information.
  7. If the Notification has been found to be unfounded, the Authorised Person shall advise the Notifier that, based on the facts set out in the Notification and other facts known to him or her, he or she does not suspect that a breach of the Rules has occurred or has found that the Notification is based on false information.
  8. The authorised person shall keep a record of Notifications in accordance with the legislation.

This Directive shall enter into force on 1 January 2007. 1. 2024

In Brno on 28. 12. 2023

Oční studio Aleš Žejdl s.r.o.