In accordance with the obligations imposed on our company 2N TELEKOMUNIKACE a.s., Id. No.: 26183960, with its registered office at Prague 4, Modřanská 621/72, Postal Code 14301, by Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (“Whistleblower Protection Act”), we have implemented an internal whistleblowing system.

The internal whistleblowing system is a set of procedures and tools for receiving and handling reports, protecting the identity of the whistleblower and other persons, protecting the information contained in the report and communicating with the whistleblower.

Below is a summary of the basic information that you, as the whistleblower, may be interested in.

Who can be a whistleblower and what reports are subject to statutory protection?

A whistleblower may be any natural person who, in connection with work or other similar activities for our company or other company (employee of our company, trainee, intern, co-operating self-employed person, member of a body of our company, employee of our company’s business partner and other persons listed in Section 2(3) of the Whistleblower Protection Act), has become aware of a possible unlawful conduct that has occurred or is about to occur at our company and which

• has the features of a criminal offence;
• has the features of an infraction for which the law stipulates a fine with the upper limit of at least CZK 100,000;
• violates the Whistleblower Protection Act; or
• violates another legal regulation or regulation of the European Union in specified areas (corporate income tax, prevention of money laundering and terrorist financing, consumer protection, product requirements including product safety, environmental protection, competition, public auctions and public procurement, personal data protection, etc.).

In this way you can, for example, report suspected:

• Fraud
• Human rights violations
• Money laundering or violations of sanction laws
• Anti-Competitive practices
• Corruption, bribery, or conflicts of interest
• Inadequate financial or non-financial recordkeeping
• Improper use of company resources
• Unlawful activities in environmental, health and safety area
• Unlawful activities in public procurement and public tenders area
• Disclosure of confidential information
• Discrimination or harassment
• Retaliation against anyone raising a concern in good faith.

How can I submit a report through the internal whistleblowing system?

Our company allows the whistleblower to submit a written and oral report. Notifications shall be made to the competent person appointed by our company for this purpose:

Competent person: Jana Krajcarová, Chief HR Officer (CHRO), tel.: +420 225 271 987, e-mail: whistleblower@2n.com, contact address: Modřanská 621/72, 143 01 Prague 4, Czech Republic.

a) Written report:

• in electronic form to the e-mail address of the competent person, to which no one else has access;
• in printed form by post to the address of the competent person; written reports must be submitted in a sealed envelope with the designation “DO NOT OPEN – WHISTLEBLOWER”, otherwise it is not possible to ensure sufficient protection of the whistleblower;

b) Oral report:

• by telephone to the competent person on business days from 9:00 a.m. to 3:00 p.m.;
• at the request of the whistleblower also in person.

An audio recording or a written record which faithfully captures the substance of the oral report shall be made of the oral report. An audio recording of the oral report may only be made with the consent of the whistleblower. The competent person shall allow the whistleblower to comment on the recording or transcript of the audio recording, if made, and the statement of the whistleblower shall be enclosed with the recording or transcript.

Is it possible to submit anonymous reports?

Our company also allows you to make anonymous reports. The competent person shall not ascertain the identity of the whistleblower and the deadlines for notification of receipt of the report and the result of the investigation of the report shall not apply. Anonymous reports are not subject to protection under the Whistleblower Protection Act until the potential ascertainment of the whistleblower’s identity.

Information on receipt of the report, deadline for assessing the report

The competent person shall notify the whistleblower no later than 7 days of receipt of the report. The competent person shall not notify the whistleblower if he/she so requested or it is clear that the notification would reveal the identity of the anonymous whistleblower.

The competent person shall assess the justification of the report within 30 days of the date of receipt of the report. Within the same deadline, he/she shall also inform the whistleblower of the results of the assessment. In complex cases, the period may be extended by 30 days at most twice. The competent person shall notify the whistleblower of the extension and the reasons that led to the extension before the expiry of the deadline.

If the competent person assesses the report as unjustified, he/she shall inform the whistleblower of the possibility to file a report with a public authority.

Submission of a report through the external system of the Ministry of Justice

In addition to submitting reports through the company’s internal whistleblowing system, whistleblowers may submit reports through an external whistleblowing system established by the Ministry of Justice.

The report may be submitted to the Ministry of Justice orally, in writing, in person (at request of the whistleblower) or at https://oznamovatel.justice.cz/chci-podat-oznameni/.

Further details regarding the submission and handling of reports submitted via the external whistleblowing system of the Ministry of Justice are available at: https://oznamovatel.justice.cz/informace-pro-oznamovatele/.