This notification system is intended for reporting infringements related to the agenda of Deutsche Telekom Services Europe Czech Republic s.r.o. (DTSE CZ).

Information prior to submitting a notification

Persons responsible and channels for notification

The persons in charge of receiving and handling notifications are representatives of the Compliance Department (Compliance Officer DTSE CZ and Compliance Officer Deutsche Telekom Services Europe Slovakia s.r.o. (DTSE SK)).

Notifications can be made:

1. in writing by email to: Whistleblowing_DTSECZ@telekom.com

2. by telephone at the numbers listed below (a written record of the conversation will be made)

3. in person (an appointment can be arranged by email as above or by telephone at the numbers below)

4. to the Ministry of Justice via the designated online form, if the notification cannot be submitted to the appropriate person for processing and the notifier chooses to use this option.

Contacts

– Compliance Officer DTSE CZ: +420 734 220 443

– Compliance Officer DTSE SK: +421 901 741 428

Deutsche Telekom Services Europe Czech Republic s.r.o. does not exclude receiving notifications from persons who do not perform work or any similar activity for the obliged entity.

What infringements can be reported

The notification shall contain information about a possible infringement that has occurred or is about to occur in relation to a person for whom the notifier, even indirectly, has  performed or is performing work or other similar activity, or in relation to a person with whom the notifier has been or is in contact in connection with the performance of work or other similar activity, and which

1. has the elements of a criminal offence,

2. has the characteristics of a misdemeanour for which the law provides for a fine with an upper limit of at least CZK 100 000,

3. violates the Whistleblower Protection Act, or

4. violates another legal regulation or a regulation of the European Union in the field of

        1. financial services, statutory audit and other assurance services,

financial products and financial markets,

        2. corporate income tax,

        3. the prevention of money laundering and terrorist financing,

        4. consumer protection,

        5. compliance with product requirements, including product safety,

        6. transport, transport and road safety,

        7. protection of the environment,

        8. food and feed safety and animal health,

        9. radiation protection and nuclear safety,

        10. competition, public auctions and public procurement,

        11. protection of internal order and security, life and health,

        12. protection of personal data, privacy and security of electronic communications networks and information systems,

        13. the protection of the financial interests of the European Union, or

        14. the functioning of the internal market, including the protection of competition and State aid under EU law.

Whistleblower protection

1. Protection is afforded to a whistleblower who makes a notification:
a. through the internal notification system,
b. to the Ministry of Justice, or
c. publicly, provided that:

            1. the whistleblower has made a notification through the internal notification system and to the Ministry, or only to the Ministry, and no appropriate action has been taken within the time limits laid down by law (for example, the validity of the notification has not been assessed or no suitable remedial or preventive measure has been adopted), or

            2. the whistleblower has reasonable grounds to believe that the unlawful conduct described in the notification may lead to an imminent or obvious threat to internal order or security, life or health, the environment or another public interest, or to irreparable harm, or

            3. the whistleblower has reasonable grounds to believe that, if the notification is made to the Ministry, there is an increased risk that he or she, or another person, will be subjected to retaliation.

2. Protection from retaliation is also provided to a person who has made a notification to a public authority competent under another legal provision or directly applicable EU regulation.

3. Protection from reprisal does not apply to a person who has made a notification without having reasonable grounds to believe that it is based on true information (a “knowingly false notification”).

Investigation of notifications

1. Notifications may be made orally or in writing through the internal notification system. If the notifier so requests, the competent person must receive the notification in person within a reasonable time, but no later than 14 days from the date of the request.

2. The competent person must inform the notifier in writing of the receipt of the notification within 7 days of receiving it, unless:
a. the notifier has expressly requested not to be informed of the receipt, or
b. it is clear that such confirmation would disclose the identity of the notifier to another person.

3. The competent person assesses the validity of the notification and informs the notifier in writing of the results within 30 days of receipt. In factually or legally complex cases, this period may be extended by up to 30 days, and this extension may be used at most twice. The notifier must be informed in writing of the extension and its reasons before the original period expires. The rules on written confirmation apply accordingly.

4. If, when assessing the notification, the competent person finds that it is not a notification under the Whistleblower Protection Act, the notifier is informed of this in writing without undue delay.

5. If the notification is considered justified, the competent person proposes to the obliged entity measures to prevent or remedy the unlawful situation. If the notification concerns an obliged entity for which the notifier does not perform work or similar activity, the competent person proposes remedial measures to the entity for which the notifier performs such activity, unless the nature of the matter excludes this. If the obliged entity does not implement the measure proposed by the competent person, it must take another appropriate measure to prevent or remedy the unlawful situation, except where the proposed measure concerns another entity. The obliged entity informs the competent person without delay of the measures taken and the competent person then informs the notifier in writing without undue delay.

6. If the notification is not considered justified, the competent person informs the notifier in writing without undue delay that, on the basis of the facts stated and the circumstances known, no suspicion of an infringement has been found, or that the notification is based on false information, and advises the notifier of the right to submit a notification to a public authority.