Whistleblowing
Information on reporting unlawful conduct
Below you will find options for reporting illegal activities (whistleblowing) that may concern Birne by Direct s.r.o. (hereinafter referred to as the "Company") pursuant to Act No. 171/2023 Coll., on the protection of whistleblowers, and Act No. 253/2008 Coll., on certain measures against money laundering and terrorist financing (hereinafter referred to as the "Legal Regulations").
Who can submit a report
A report may be submitted to the Company by a natural person who performs work for the Company in connection with:
employment,
self-employment,
rights associated with membership in a legal entity,
the function of a member of a legal entity's body, who is elected, appointed or otherwise called to office,
voluntary activities, professional practice and internships,
rights and obligations arising from a contract whose subject is the provision of supplies, services, construction works or other similar performance,
or applying for a job or other similar activity.
What conduct can be reported
A report may be made about possible unlawful conduct that has occurred or is about to occur at the Company and that:
1) has the characteristics of a criminal offense,
2) has the characteristics of an offense for which the law provides for a fine, the upper limit of which is at least CZK 100,000,
3) violates Legal Regulations or
4) violates another legal regulation of the Czech Republic or a regulation of the European Union in the area of:
- financial services, statutory audit and other assurance services, financial products and financial markets,
- corporate income tax,
- prevention of money laundering and terrorist financing,
consumer protection,
- environmental protection,
- economic 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,
- protection of the financial interests of the European Union, or
- functioning of the internal market, including protection of competition and state aid under European Union law, and possibly others.
How to make a notification
The notifier has the right to submit a notification to the designated authorized person in the following ways:
electronically to the email address whistleblowing@direct-auto.cz, where the subject of the notification must be marked as "Confidential" with the name of the specific Company to which the notification relates, and intended only for the attention of the authorized person;
in writing by letter addressed explicitly to the authorized person's own hands at the address
Erudit advokátní kancelář, s.r.o.
Nové sady 996/25
602 00 Brno.
The sealed envelope must be explicitly marked with the words DO NOT OPEN – CONFIDENTIAL and the name of the specific Company to which the notification relates. In such a case, only the authorized person may open this envelope;
by phone at tel. number 234 043 399, on weekdays between 8 AM and 4 PM;
in person after prior telephone or electronic arrangement with the authorized person, on weekdays between 8 AM and 4 PM.
For oral notifications, the authorized person shall, with the consent of the notifier, make an audio recording or transcript and allow the notifier to comment on the transcript or the audio recording.
Notifications can also be submitted anonymously. In order for the notifier to be informed about the progress and outcome of the resolution, it is necessary to include in the anonymous notification, for example, a P. O. BOX address or an email address created once solely for the purpose of contacting the notifier by the authorized person, or other contact information through which the authorized person can contact the notifier.
The notifier also has the option to submit a notification through an external reporting system,
- which, in the case of a notification of a violation of Act No. 253/2008 Coll., on certain measures against money laundering and terrorist financing, is exclusively the system for receiving notifications established by the Financial Analytical Unit (https://fau.gov.cz),
- which, in the case of a notification of a violation of another obligation under Act No. 171/2023 Coll., on the protection of whistleblowers, is the system established by the Ministry of Justice (https://oznamovatel.justice.cz/chci-podat-oznameni/). Through the system for receiving notifications established by the Ministry of Justice, it is not possible to submit notifications of violations of obligations under the Act on Certain Measures against Money Laundering and Terrorist Financing.
To achieve the fastest and most effective resolution of notifications, we recommend using the internal notification system of the Companies.
Responsible Person
Reports within the Companies are handled solely by the designated responsible person, who is:
Karolína Lancůchová
email: karolina.lancuchova@erudit.cz
phone: 234 043 399
The provided email is solely for answering questions regarding reporting or for arranging a personal meeting with the responsible person. It is not intended for submitting reports. To submit a report, please use the options described above.
A whistleblower who knowingly submits a false report cannot claim protection under the Legal Regulations and risks possible penalties.