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Whistleblowing TŽ

We, the company TŘINECKÉ ŽELEZÁRNY, a. s., with registered office at Průmyslová 1000, Staré Město, 739 61 Třinec, ID No. 18050646, registered in the Commercial Register maintained by the Regional Court in Ostrava, Section B, Insert 146, in accordance with our Company's Principles of Conduct and our policy of whistleblowing and whistleblowing, inform about the following:

Information on the Internal Notification System

I. ESTABLISHMENT OF THE INTERNAL NOTIFICATION SYSTEM

We have established an internal notification system (the "Internal Notification System") for the purpose of notification of our infringements in the areas defined by Act No. 171/2023 Coll., on the protection of whistleblowers, or Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law according to Section II (the "Notification") by the individuals listed in Section III (the "Notifier")

II. DEFINED AREAS OF EUROPEAN UNION LAW

Our Internal Notification System is designed for the submission of Notifications of infringements

  1. having the characteristics of a criminal act
  2. having signs of an offence, for which the law sets a fine with an upper limit of CZK 100,000 and more
  3. violating Act No. 171/2023 Coll., on the protection of whistleblowers
  4. violating another legal regulation or European Union regulation falling within the following areas:
  • financial services, mandatory audit and other verification services, financial products and markets;
  • corporate income taxes;
  • prevention of legalization of criminal proceeds and terrorist financing;
  • consumer protection;
  • product safety and compliance;
  • transport security;
  • environmental protection;
  • food and feed safety, and animal protection 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 privacy and personal data and security of networks and information systems;
  • protection of personal data, privacy and security of electronic communications networks and information systems;
  • protection of the European Union's financial interests.

The functioning of the internal market, including the protection of economic competition and state aid according to European Union law.

III. NOTIFIER

A whistleblower who may use our Internal Reporting System to submit a Notification is an individual who works for us, which means, in particular:

  • performing a job, professional practice, or internship.
  • performing a function in the bodies of our trading company;
  • providing services for our company;
  • performing activities under the supervision or direction of our contractors and suppliers and their subcontractors, and who has obtained information about our wrongful conduct under Section II in connection with such work, or the performance of similar activities.

Work or a similar activity also means applying for any of the above-mentioned activities.

From submitting a Notice we do not exclude any persons who perform work or similar activities for us.

IV. METHOD OF FILING A NOTICE

You may submit a Notification through our Internal Notification System to

  1. by email, which should be sent to the email address oznameni@trz.cz, which we have established solely for the purpose of receiving Notices;
  2. by telephone via the telephone line +420 558 532 399; we also request that this method of submitting a Notice be used during normal business hours;
  3. in writing by post sent to the address of our registered office Průmyslová 1000, Staré Město, 739 61 Třinec directly to the Head of Inspection&Audit Department; we hereby also request, in order to preserve confidence, that this mail be addressed directly to the Head of Inspection & Audit Department for delivery via a legal entity, with the address of the mail being indicated as follows:

Head of the Inspection & Audit Department
TŘINECKÉ ŽELEZÁRNY, a. s.
Průmyslová 1000
Staré Město
739 61 Třinec
Czech Republic

and "WHISTLEBLOWING" will be clearly marked on the notification.

For these purposes, prefer to send the notification in such a way that its sender is not obvious from the notification. You will be notified that the Notice has been delivered to us via the contact details included in the Notice.

  1. in person at the building located at Závodní 819, Staré Město, 73961 Třinec (this is the Main Gate building), Inspection & Audit Department; we hereby also request that this method of submitting the Notification be used during normal working hours and, if possible, after prior arrangement by e-mail pursuant to point 1. or by telephone pursuant to point 2.

Please ensure that the Notice contains the following information: Your name, surname and date of birth or other information from which your identity can be deduced. In order to be informed about the receipt and the method of processing your Notice, please also include your contact details. Only a person bound by confidentiality will be informed about your identity. However, without your proper identification, it may not be possible to properly investigate the Notice and undertake corrective measures.

When using the e-mail oznameni@trz.cz, only the Head of the Inspection & Audit Department will be notified of all Notifications submitted and the identity of the Notifier. Head of the Inspection & Audit Department, who is the relevant person, will be also notified with notifications made via the phone line +420 558 532 399.

V. PROTECTION OF THE NOTIFIER

We will ensure that the Notification has been submitted through our Internal Notification System,

  • protect the identity of the Notifier;
  • protect the Notifier and other persons entitled to such protection under the law from retaliation.

VI. NOTICE

We assess the reasonableness and truthfulness of each Notification. If the Notice is reasonable and true, we will take corrective action.

We will defend ourselves if a Notifier knowingly provides false information in a Notification and/or makes a Notification in order to harm our business.

Making a notification is not a breach of banking secrecy, contractual confidentiality and obligations to maintain confidentiality under the tax code or other types of confidentiality, with the exception of obligations:

  1. to ensure the protection of classified information and information, the disclosure of which could obviously endanger ongoing criminal proceedings, or the protection of special facts according to the law regulating crisis proceedings,

  2. maintain confidentiality when performing activities:

a) notary public, notary candidate and notary assistant,

b) a public prosecutor, assistant public prosecutor and legal guardian,

c) lawyer and legal assistant,

d) bailiff, bailiff candidate and bailiff clerk,

e) judge, judge of the Constitutional Court, assistant judge and judicial candidate,

f) employees of a notary public, a bailiff, a lawyer and an employee of a company through which the lawyer practices advocacy as a partner in accordance with the law governing the practice of advocacy, or a similar foreign company, or another person who participates in the provision of legal services within such a company.

  1. maintain confidentiality when providing legal assistance in proceedings before a court or other public authority, or

  2. maintain confidentiality in the provision of health services.

VII. INFORMATION ABOUT THE OPPORTUNITY TO SUBMIT A NOTICE TO THE MINISTRY OF JUSTICE

Notifiers can also submit the Notification orally or in writing to the Ministry of Justice. You can use the website to submit a written notification to the Ministry of Justice https://oznamovatel.justice.cz/chci-podat-oznameni/