A report is understood to be an oral or written notification by a natural person, the content of which is information about possible unlawful conduct that the whistleblower learned of in connection with work or other similar activity that they performed, or applied to perform, at IBG Česko s.r.o.

The content of a report is information about possible unlawful conduct that:

  • has the characteristics of a criminal offence,
  • has the characteristics of a misdemeanour for which the Act on the Protection of Whistleblowers sets a fine with an upper limit of at least CZK 100,000,
  • violates the Act on the Protection of Whistleblowers or another legal regulation or EU regulation in the areas defined in Section 2(1)(d) of the Act on the Protection of Whistleblowers.

Whistleblower

A report may be filed by any natural person who performs or has performed work or other similar activity in connection with which the report is filed. Whistleblowers may include employees, the company’s statutory representatives, job applicants, interns, contractual suppliers providing deliveries, services, construction work or similar performance, etc., pursuant to Section 2(3) and (4) of the Act on the Protection of Whistleblowers.

IBG does not exclude accepting reports from a person who does not perform work or other similar activity for the obliged entity under Section 2(3)(a), (b), (h) or (i) of the Act on the Protection of Whistleblowers.

How to submit a report

A report can be submitted through the internal reporting system, the external reporting system via the Ministry of Justice, by publication, or directly to the relevant public authorities.

Internal reporting system

The whistleblower submits a report through the internal reporting system exclusively to the designated person:
Compliance manager: RNDr. Karel Vulterin
Phone: +420 603 437 078
E-mail: compliance@ibg.cz

  1. Sending electronically — via the reporting form to the e-mail address compliance@ibg.cz.
  2. Sending in paper form — via a printed form, in a sealed envelope marked “DO NOT OPEN — WHISTLEBLOWER”, delivered to the attention of the Compliance manager: Karel Vulterin, IBG Česko s.r.o., V Pískovně 2053, 278 01 Kralupy nad Vltavou.
  3. By depositing it in the box for receiving paper submissions — a mailbox marked “Report” located at reception.
  4. Orally — by phone or in person after a telephone arrangement with the designated person, within a reasonable period, but no later than 14 days from the day the whistleblower requested it. A record shall be made of an oral report that faithfully captures its substance. In-person meetings take place only in the Compliance manager’s office.

A report must be comprehensible and specific; it must be clear what conduct it concerns, including the identification of the person against whom the report is directed, if their identity is known. The report must contain details of the name, surname and date of birth, or other information from which the whistleblower’s identity can be inferred, and the whistleblower’s contact address.

The Compliance manager may not disclose data from the report to a third party who is not also designated as an authorised person, except when passing on information to the relevant public authority under other legal regulations. The whistleblower is always informed of such a procedure in advance.

Report handling procedure

Within 7 days of receiving the report, the Compliance manager shall confirm receipt of the report to the whistleblower, unless the whistleblower has explicitly requested not to be notified of its receipt, or it is clear that such notification would disclose the whistleblower’s identity to another person.

The Compliance manager shall assess the merits of the report and, no later than 30 days from the date of its receipt, shall notify the whistleblower in writing of the results of the assessment of the report. In complex cases, this period may be extended by up to 30 days, but no more than twice.

External reporting system

A report can also be submitted via the Ministry of Justice — for more information see the ministry’s website (justice.cz). Submitting a report to the ministry is not conditional on first submitting the report through the internal reporting system.

Protection of whistleblowers

The protection of whistleblowers is governed by Act No. 171/2023 Coll., on the Protection of Whistleblowers, as amended. The Act on the Protection of Whistleblowers does not apply to anonymously submitted reports, unless the identity of an originally anonymous whistleblower is revealed.

The person for whom the whistleblower performs work or other similar activity may not allow the whistleblower or other persons defined by law (a person who provided assistance, a person close to the whistleblower, a colleague, etc.) to be subjected to retaliatory measures.

Given the circumstances and information available to the whistleblower at the time of the report, they should have sufficient grounds to believe that the facts they are reporting or disclosing are true. It is therefore not permitted to report facts known to be false — such conduct may be considered a misdemeanour subject to a fine.