Internal Whistleblowing System
Generali CEE Holding, B.V. (hereinafter "GCEE") has established an Internal Whistleblowing System in accordance with Act No. 171/2023 Coll. on the Protection of Whistleblowers, which is used by GCEE to report violations1 that have occurred or are about to occur in connection with our company. GCEE does not exclude receiving notifications also from persons who do not perform work or other similar activities for GCEE. The Whistleblower Protection Act can be found here: https://aplikace.mvcr.cz/sbirka-zakonu/.
Competent person and options for safe notification: Ing. Kateřina Kroupová
- Email: ochrana_oznamovatele_GCEE@generali.com
- Phone: +420 604 729 411
The telephone line is available for receiving notifications on Mondays and Wednesdays from 10 a.m. to 2 p.m. A written record of the notification will be made. The call is not recorded.
Notification can also be made in person. In this case, please make an appointment with the competent person using the email or phone number above.
Send the notification to: Generali CEE Holding, B.V., Na Pankráci 1658/121, 140 21, Prague 4 / P.O. Box 39
If the notification is submitted by post, the envelope must be marked:
"DO NOT OPEN - deliver to K. Kroupová“
The notification must be specific and clear. It must be clear from the notice which person is involved and what conduct it relates to so that it can be properly investigated.
In the notification, the whistleblower shall state his name, surname and date of birth or other information from which his identity can be determined. It is useful to provide also a telephone number or email through which the competent person will communicate with you.
The notification can also be made anonymously. A notification is considered anonymous if the whistleblower does not provide his/her name or other identifiable information. In the case of an anonymous notification, it is also advisable to provide a telephone number or email through which the competent person can contact you. Keep in mind that not being able to contact the whistleblower may adversely affect the investigation of the report.
Are there other ways to make a notification?
Yes, in addition to our Internal Whistleblowing System, you can use the external notification system set up by the Ministry of Justice (for more information, see https://oznamovatel.justice.cz/).
Under the conditions of the Whistleblower Protection Act, it is possible to publish2 a notification in some cases.
What are the obligations of the whistleblower?
The whistleblower should, in the light of the circumstances and the information available to him/her at the time of the notification, have reasonable grounds for believing that the facts notified or disclosed to him/her are authentic and true. Therefore, facts knowingly false cannot be communicated. Such conduct may be sanctioned.
In obtaining documents to substantiate the facts reported, the whistleblower should not conduct unlawfully or in a way to constitute a criminal offence.
The whistleblower should conduct in the public interest and in the good faith belief that the report he/she is making is based on credible facts and evidence.
The whistleblower should be able to identify the area of the violence and consider what verifiable information he/she can provide about the violation being reported. The extent and quality of the information provided can have a positive impact on the way the notification is investigated.
Procedures after notification
- Within 7 days the competent person shall notify the whistleblower in writing of the receipt of the notification. Exceptions to this are situations where the whistleblower explicitly requests the competent person not to notify him/her of the receipt of the notification or where it is clear that notification of the receipt would reveal the identity of the whistleblower to another person.
- The competent person shall assess the validity of the notification and inform the whistleblower in writing of the results of the assessment within 30 days of receipt of the notification. In factually or legally complex cases, this period may be extended by additional 30 days, but not more than too times.
- If the competent person concludes that the notification is not a notification under the Whistleblower Protection Act, the competent person shall inform the whistleblower in writing without any delay.
- If the notification is found to be substantiated, then the competent person shall propose to the GCEE measures to prevent or remedy the violation. The GCEE shall inform the competent person of the measure taken, who shall inform the whistleblower in writing without any delay.
- If the notification is found not to be substantiated, the competent person shall, without any delay, inform the whistleblower in writing that, on the basis of the facts stated in the notification and the circumstances known, the competent person does not find that a violence has been suspected or that the notification is based on false information, and shall advise the whistleblower of the right to submit a notification through the external notification channel of the Ministry of Justice.
Through the Internal Whistleblowing System notifications that contain information about a possible violations that has occurred or is about to occur in the GCEE can be reported. Simultaneously the violations:
- has the elements of a criminal offence,
- has the characteristics of an offence for which the law provides for a fine of at least CZK 100 000,
- violates the Whistleblower Protection Act; or
- violates another legal regulation or a regulation of the European Union in the field of:
- financial services, statutory audit and other assurance services, financial products and financial markets,
- corporate income tax,
- the prevention of money laundering and terrorist financing,
- consumer protection,
- compliance with product requirements, including product safety,
- transport and road safety,
- protection of the environment,
- food and feed safety and animal health,
- radiation protection and nuclear safety,
- 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,
- the protection of the financial interests of the European Union,
- the functioning of the internal market, including the protection of competition and state aid under European Union law.
2 The Whistleblower Protection Act allows for the reporting of violations by publication, e.g. via social networks, in the media, etc., but only under certain conditions. The conditions for publication are met if the whistleblower:
- he/she has submitted a notification through the Internal Whistleblowing System and the external notification system set up by the Ministry of Justice and no appropriate action has been taken within the time limits set out in this Act, in particular the competent person has not assessed the reasonableness of the notification, the obliged entity has not taken other appropriate action to prevent or remedy the unlawful condition or a Ministry of Justice has not assessed the notification,
- has reasonable grounds to believe that the violation may lead to an imminent or obvious threat to internal order or security, life or health, the environment or other public interest, or to irreparable harm; or
- has reasonable grounds to believe that, if the notification is made to the Ministry of Justice, there is an increased risk, given the circumstances of the case, that he/she or another protected person will be subjected to retaliation or that the proper handling of the notification by the Ministry of Justice is threatened.