Whistleblowing

Statement of PKF APOGEO Group, SE on the Act on Criminal Liability of Legal Entities

In accordance with its Criminal Management System, PKF APOGEO Group, SE, ID No. 24817601 with its registered office at Rohanské nábřeží 671/15, Karlín, 186 00 Prague 8, registered under file no. No. H 322 at the Municipal Court in Prague (hereinafter referred to as “PKF APOGEO”) hereby declares the following:

Statement

PKF APOGEO does not tolerate any form of criminal activity.
PKF APOGEO always carries out its activities in full compliance with all legal and ethical requirements.
PKF APOGEO consistently ensures that all employees and all responsible persons always fully comply with the laws of the Czech Republic as well as the internal regulations of PKF APOGEO and draw consequences from breaches.
PKF APOGEO fully subscribes to the social interest in preventing the commission of a crime, as well as averting the consequences of a crime committed, all of which is one of PKF APOGEO’s main priorities.
PKF APOGEO fully embraces the social responsibility that arises from its specific position.
PKF APOGEO has implemented a Criminal Management System, which is a comprehensive system of internal corporate measures and procedures for preventing, detecting and responding to potential criminal conduct, and which is part of PKF APOGEO’s corporate culture.
The basic binding internal regulations of the Criminal Management System compliance programme are the Internal Regulation – Criminal Management System and the Code of Ethics of PKF APOGEO.
As part of its activities, PKF APOGEO makes every effort to prevent the commission of unlawful acts by persons listed in Section 8 of the Act on Criminal Liability of Legal Entities and to avert the consequences of the crime committed.
In particular, the Criminal Management System includes measures and procedures for criminal prevention, detection and response. PKF APOGEO considers all measures to be adequate, reasonable, effective and sufficient, especially from a practical point of view and corresponding to the actual intensity of the imminent risk.

Criminal Management System – Guide

CMS is a system of internal measures and procedures for the prevention, detection and response to potential criminal acts, and it is part of PKF APOGEO’s corporate culture and serves to prevent the commission of a crime and to avert the consequences of a crime. Everyone is obliged to act legally, always in accordance with the CMS and to report suspected violations of the CMS.

The CMS is based on the following internal regulations available at PKF APOGEO Group, SE SharePoint:

PKF APOGEO Internal Regulation – Criminal Management System (including a description of the internal whistleblowing system)
Code of Ethics
Other internal regulations and on legislation, in particular the Whistleblower Protection Act, the Criminal Code, the Act on Criminal Liability of Legal Entities and the Code of Criminal Procedure
The person responsible for the CMS is: HR manager (competent person)

Reporting a suspected violation to CMS is possible in several ways that ensure confidential reporting, they are listed on pages 3 and 4 of this document. Due to properly reported breach to CMS, the reporting person cannot be impaired in any way.

Notifications within the Criminal Management System

The specific objective of the CMS in the area of detection is to set up effective mechanisms and ensure effective detection of conduct violating the CMS or unethical conduct while maintaining the confidentiality of the notification and the whistleblower, and any appropriate response.

PKF APOGEO has a system for reporting events or conduct that may be a violation of the CMS or Code of Ethics. This notification system contains several options – a network of options – and covers all possible ways of reporting (verbal, written, electronic, including acceptance of anonymous reports). This whistleblowing system is fully applicable to any suspicion of illegal or unethical conduct, including suspicion of corruption.

Reporting a breach of CMS or Code of Ethics will not be sanctioned, even indirectly, unless it is made with the intention of harming a person with false information, when in doubt, the whistleblower's conduct is considered to have been done in good faith, unless proven otherwise.

Any third party may also make a notification.

In an urgent case, especially for the immediate prevention of committing or averting the consequences of a crime, everyone is obliged to report in a way that allows for an immediate response by the responsible person.

The content of the detection means (e-mail address, mailbox at the PKF APOGEO headquarters reception) are checked every working day.

Each notification is assigned a unique designation and is duly registered.

The HR manager is immediately informed of any report of a breach of CMS or Code of Ethics.

Whistleblower protection

The notification system can be used securely and confidentially. The reporting methods allow anonymous reporting by persons concerned, but also by any third party. All reports will be investigated appropriately, i.e. regardless of their anonymous nature.

Electronic notification

Notification of a breach of CMS or the Code of Ethics can be made to the following e-mail address: whistleblowing@pkfapogeo.cz

Written or personal notification

Notification of a breach of CMS or the Code of Ethics can be made in writing or in person at the following postal address:
PKF APOGEO Group, SE, ROHAN BUSINESS CENTRE, Reception B, Rohanské nábřeží 671/15, 186 00 Prague 8. Write on the envelope – “To the relevant person – DO NOT OPEN”

Telephone notification

A report of a breach of the CMS or the Code of Ethics can be made by telephone to one of the following responsible persons:

HR manager: +420 724 474 967
COO: +420 601 156 078

Notification to the public prosecutor or police authority

A whistleblower may report to the public prosecutor or the police under the Code of Criminal Procedure (Section 158(2) of the Code of Criminal Procedure).

OLAF

Anonymous reports of suspected fraud or other serious irregularities that may have a negative impact on EU funds, whether in terms of revenues, expenditures or assets owned by the EU institutions, or suspected serious misconduct by staff of the EU institutions, can be made via the web form on the website of the European Anti-Fraud Office (OLAF):

http://ec.europa.eu/anti_fraud/investigations/report-fraud/index_cs.htm
(http://ec.europa.eu/anti-fraud/olaf-and-you/report-fraud_en)

or to the postal address:

European Commission
European Anti-Fraud Office (OLAF)
1049 Brussels
Belgium