This document sets out to inform reporting persons of the options available to them when reporting suspected illegal or unethical activity related to CPIPG operations. This document describes types of suspicions that should be reported, the rights of reporting persons and protections afforded to them, procedures for investigating reports and the notifying of reporting persons of the outcomes of such investigations. The document is governed by the EU Directive on the protection of persons who report breaches of European Union law and associated legal regulations specific to individual countries.
This document is binding for CPIPG companies and employees. It provides information to CPIPG employees and other persons regarding channels available for submitting reports.
The term “whistleblowing” is used to describe a disclosure by an employee or another person of suspected wrongdoing within an organisation. It is essential that reporting persons, or whistleblowers, feel safe and report their suspicions in early stages of the suspect activity.
CPIPG supports its employees and other persons in reporting matters that are deemed to contravene the rules and/or values upheld by the CPIPG group. By implementing its Ethics Line, CPIPG makes available various reporting channels that ensure the protection of the reporting person’s identity. Where the identity of the reporting person is known, it is never disclosed without the explicit consent of the reporting person. Similarly, no other information is disclosed that could be used to infer a reporting person’s identity (unless required by law).
Timely reporting of suspected wrongdoings is desirable and beneficial as it facilitates the speedy investigation of the reported matter and improves the chances of mitigation of any negative impacts.
Reports may be filed by natural persons who have become aware of illegal activity in connection with their work or similar activity performed for CPIPG. Such persons include:
Persons whose legal relationship with CPIPG is yet to commence shall be subject to this document only to the extent to which the reported information was obtained as part of pre-relationship negotiations, e.g. during the recruitment and selection of potential employees.
The Ethics Line can be used to report suspicions of the following types of wrongdoing:
This document is not concerned with grievances related to employment and/or relationships in the CPIPG workplaces. Solutions to work-related matters or any other issues not covered by this document should be sought from CPIPG Human Resources department. Any matters related to occupational health and safety should be reported in accordance with procedures defined in CPIPG internal regulations, unless the issue in question is serious and there exists a reasonable uncertainty about the advisability of reporting it through the standard channels. This document also does not apply to any product or service-related complaints or complaints about unsatisfactory quality.
Reporting persons must have reasonable grounds for believing that the matter to be reported is concerned with one or more of the areas covered by this document. It is possible to report past, current or likely future matters. There is no requirement for definitive supporting evidence to be included with the report. Disclosures need only be made in good faith given the circumstances at the time of the disclosure.
If there is doubt as to whether a suspicion should be reported, it is advisable to discuss the matter with a superior or another person in a managing position who can be trusted and is not involved in the matter in any way. It is important not to share any information about possible suspicions with anyone involved in the matter or any third party other than the person from whom confidential advice is sought.
Anyone reporting a matter falling outside the scope of whistleblower protection legislation will be notified of the fact without undue delay.
It is recommended that all relevant suspicions be reported using the Ethics Line in the manner described below. This approach ensures a timely response and investigation.
It is best to use the Ethics Line portal that acts as a useful guide through the reporting process. The Ethics Line is available on this link: https://ethicshotline.eu/en/home/?client=28474651.
The acceptance, administration and impartial investigation of reports is conducted on behalf of CPIPG by employees of BDO Audit s.r.o., with its registered offices at V parku 2316/12, Chodov, postal code 148 00, Prague 4, reg. No.: 45314381 (“BDO”). They have been authorised by CPIPG to act as “competent persons” as per whistleblower protection legislation. Additional information is available on the Ethics Line portal.
When filing a report using the Ethics Line, reporting persons will be asked to specify in particular the following:
It is also possible to provide name and contact information. Such information may speed up the investigation considerably, but its inclusion is voluntary. If a report is to be made by other means instead of the Ethics Line portal, the reporting person will be asked to provide at least the information specified above.
Reports may also be filed by telephone, on workdays between 9am and 4pm, in Czech or English, on the following number: +420 241 046 199.
Telephone number for reporting in Poland: +48 607 101 080, available on workdays from 9am to 4pm.
Telephone number for reporting in Hungary: +36 70 947 9152, available on workdays from 9am to 4pm.
The above telephone numbers are also available for arranging a meeting in person.
It is understandable that potential reporting persons may be apprehensive about reporting their suspicions and possible consequences befalling them. CPIPG has developed this document to implement a framework which ensures that CPIPG employees and third parties are listened to and can share their justified suspicions of wrongdoing without fear of retaliation. CPIPG thus ensures the protection of persons reporting their suspicions in good faith even if the suspicions subsequently prove to be unjustified. Reports made with the intention to provide knowingly false information and damage CPIPG do not enjoy such protections and may be penalised in compliance with whistleblower protection legislation.
Reporting persons may decide to file their reports anonymously. Where the reporting person shares their identity, CPIPG will not disclose any personal information without the explicit consent of the reporting person to any person other than the competent persons authorised to investigate reports. The same applies to any other information from which the identity of reporting persons could be inferred (unless required by law, such as in connection with investigation by law enforcement authorities or as part of judicial proceedings).
Persons affected by the investigation of a report are entitled to fair treatment during the course of the investigation. This includes the unbiased and objective assessment of relevant facts, the prohibition of discrimination and the protection of personal data as stipulated by applicable legal regulations.
The receipt of a report will be confirmed by BDO within seven days, unless the report is made by telephone or in person. To report in person is possible by prior telephone arrangement. When a report is filed using the Ethics Line portal, the reporting person receives a unique case number (ID) that can subsequently be used to log into the portal and monitor the progress of the case. When reports are made by other means, the reporting person is notified about the course of the investigation and the outcome if they have provided BDO with their contact information. The provision of such information is voluntary. BDO also notifies designated persons within CPIPG about the receipt of a report, together with information regarding the nature of the report.
Next, BDO evaluates whether a breach was committed as specified by whistleblower protection legislation and/or associated national legislation for the purposes of the subsequent confirming or disproving of the reported suspicion.
BDO is not authorised to share any specific information with the reporting person regarding the course of the investigation. Where possible, the reporting person will be informed as to whether the report is to be investigated or is subject to an ongoing or concluded investigation.
BDO may use a system of confidential communication with the reporting person to obtain additional information as necessary. BDO may also request a meeting with the reporting person as an opportunity for the latter to explain their suspicions in detail and provide any available evidence. The reporting person is not obliged to agree to such a meeting.
BDO may also request cooperation from any person to whom the report is related and/or other CPIPG employees who may assist in the investigation. Any information so obtained remains confidential. Any notes created will form part of the file maintained by competent persons during the investigation.
Information regarding received reports will be retained for at least five years from the date of receipt.
Should a reporting person feel at any point during the investigation that they are the subject of retaliatory measures as a result of their report, they must notify BDO of the fact at their earliest opportunity. Ay such claim will be reviewed as part of the investigation and any person found to have participated in any retaliatory measures will be treated in compliance with applicable labour law provisions.
Based on the information acquired, BDO determines whether an evaluated report is justified. The conclusions of the evaluation will be described and included in the file. Anonymised conclusions will be submitted to designated persons within CPIPG along with any recommendations for the rectification of identified shortcomings and/or mitigation of identified risks.
The reporting person will be notified of the conclusion regarding the justification of their report within 30 days from the receipt of the report. This period may be extended in complicated cases by up to 30 days, no more than twice. The reporting person will be notified of any extension of the notification period.
Where measures are introduced as a result of the report evaluation with the aim of rectifying identified shortcomings or mitigating identified risks, BDO will inform the reporting person of the fact. Neither the measures introduced nor the information provided may encroach and/or jeopardise any interest protected by law, including objectives of criminal proceedings, misdemeanour proceedings or any other proceedings regarding an activity that bears the characteristics of a misdemeanour.
Reports are also accepted by relevant public authorities:
|Competent Person||The team of competent persons consists of:
|Ethics Line||An internal reporting system that enables filing of reports using the Tool, by phone, post/e-mail and/or in person.
|Ethics Line portal||Website providing access to an online tool designed to receive reports and provide access for the purposes of monitoring the evaluation of reports.
|EU Directive on the protection of persons who report breaches of Union law||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.
|External reporting system||Reporting channels operated by relevant public authorities.
|Internal reporting system||Reporting channels operated by a third-party service provider.
|Report||Provision of information by a reporting person orally, in writing or in person, of their suspicion of an illegal or unethical activity.
|Reporting person (whistleblower)||A natural person who has become aware of an illegal or unethical activity in connection with their work or a similar activity performed for CPIPG.
|Whistleblowing||The term describes a disclosure by an employee or another person of suspected wrongdoing within CPIPG. It is essential that reporting persons feel safe and report their suspicions during the early stages of the potential wrongdoing.