Whistleblower Policy for Czech Republic

INFORMATION FOR WHISTLEBLOWERS – REPORTING UNLAWFUL CONDUCT

In the company Cattron, s.r.o., with its registered office at Minkovická 696, Liberec 463 12, Czech Republic, ID: 073 92 770, registered in the Commercial Register kept by the Regional Court in Ústí nad Labem, Section C, Insert 42880, an internal reporting system has been established in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (hereinafter referred to as the “Law“).

Below, we inform you about what actions can be reported, where to submit a report, and where you can address inquiries.

IMPORTANT INFORMATION BEFORE SUBMISSION

You can only submit truthful reports. Knowingly false reports cannot be submitted. If you do so, you may be fined up to CZK 50,000 in accordance with § 23 of the Whistleblower Protection Act. In such a case, the Law does not protect you, and further measures may be taken against you by the company, the injured party, and state authorities. You are also liable for damage caused by a knowingly false report.

What actions can be reported?

The Law allows reports to be made in several different cases. If you have information about an action that

• constitutes a criminal offense;
• constitutes an administrative offense for which the law prescribes a fine with an upper limit of at least CZK 100,000;
• violates the Whistleblower Protection Act;
• violates legal regulations or regulations of the European Union in the field of financial services, mandatory audit and other verification services, financial products and financial markets, corporate income tax, prevention of money laundering and financing of terrorism, consumer protection, transportation safety, radiation protection, transport and operation on roads, environmental protection, economic competition, public auctions and public procurement, internal order and security, life and health, personal data protection, privacy and security of electronic communication networks and information systems, protection of financial interests of the European Union or the functioning of the internal market, including competition and state aid protection under European Union law,

you can report such behavior, even anonymously.

Who handles the reports?

Your report submitted through the internal reporting system will be received and addressed by the “competent person” (as designated by the law), who is Mgr. Veronika Sudíková. The contact number for the relevant person is +420 778 440 657. Her email address is Veronika.Sudikova@cattron.com.

The competent person is bound by confidentiality and will protect your identity and the information you provided.

How to File a Report?

The report contains information about the name, surname, and date of birth, or other data from which the whistleblower’s identity can be inferred unless this identity is known to the relevant person.

The report can be submitted through a specialized communication channel operated by the company Syntrio, which guarantees the maximum security of communication and protection of the whistleblower’s identity (hence, this communication channel is operated by an external reputable provider outside the IT system of Cattron s.r.o.):

• Orally at the phone number 800 880 804.
• In person at the company’s headquarters or at another location agreed upon with the relevant person, where the submission of the report will be allowed within a reasonable period after submitting your request, but no later than within 7 days.

If you make a report in a way other than through the channels mentioned above, such a report will not be considered a report within the meaning of the Whistleblower Protection Act. The company may, therefore, process such a report differently, and you will not be protected under the Whistleblower Protection Act.

How Is the Report Handled?

Within seven days, we will confirm in writing the receipt of your report unless you have explicitly requested the recipient of the report (the relevant person) not to be notified, or the report was made anonymously, and we have no way to respond to you, or it is clear that notifying you of the receipt of the report would reveal your identity to another person.

Based on the information from you, the relevant person will investigate the circumstances of the reported conduct within the company. Subsequently, they will propose measures to prevent the continuation of the reported conduct and remedy the situation. The relevant person also monitors the acceptance and implementation of these measures.

If the report was not made anonymously and we are, therefore, able to contact you, the relevant person will notify you, no later than within 30 days of how the report was assessed and what measures were proposed. In complex cases, the deadline may be extended by up to 60 days.

If the relevant person finds, during the assessment of the validity of the report, that it is not a report according to the Law, they will notify you in writing without undue delay.

External Reporting Option

In addition to the internal reporting system, the Law also allows the use of other reporting methods. These external reporting methods include:

• Reporting through the Ministry of Justice’s reporting system, available at: https://oznamovatel.justice.cz/.
• Reporting through public disclosure, for example, in the media (but only in cases listed in § 7 (1) (c) of the Law).

Scope of Whistleblowers

Cattron s.r.o. does not exclude the acceptance of reports from individuals who do not perform work or any similar activity for the obligated entity according to § 2 (3) (a), b), h), or i) of the Law.

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