A report pursuant to Section 2(1) of the Act contains information about possible unlawful conduct that has occurred or is about to occur on the part of a person for whom the reporting person, even indirectly, has performed or is performing work or other similar activities, or on the part of a person with whom the reporting person has been or is in contact in connection with the performance of work or other similar activities, and which:

a) has the characteristics of a criminal offence,

b) has the characteristics of an offence for which the law stipulates a fine of at least CZK 100,000,

c) violates this Act, or

d) violates another legal regulation or European Union regulation in the area of

1. financial services, statutory audit and other assurance services, financial products and financial markets,

2. corporate income tax,

3. the prevention of money laundering and terrorist financing,

4. consumer protection,

5. compliance with product requirements, including product safety,

6. transport, transport and road traffic safety,

7. environmental protection,

8. food and feed safety and animal protection and health,

9. radiation protection and nuclear safety,

10. competition, public auctions and public procurement,

11. protection of internal order and security, life and health,

12. protection of personal data, privacy and security of electronic communications networks and information systems,

13. protection of the financial interests of the European Union, or

14. functioning of the internal market, including protection of competition and state aid under European Union law.

The report shall also contain information on the identity of the reporting person. For the purpose of sending notification of the results of the assessment of the report, it is necessary to provide contact details.

In accordance with legal requirements, the reporting person may make the report in writing, orally, or in person upon request. To meet this requirement, the company is introducing the following channels for its internal reporting system:

Written report:

By sending a registered letter to the company's address: INGTOP s.r.o., Nádražní 166, 517 21 Týniště nad Orlicí. The report must be submitted in a properly sealed envelope marked "TO THE ATTENTION OF THE RELEVANT PERSON – DO NOT OPEN".

By sending an email to: whistleblowing@ingtop.cz

Verbal notification:

By leaving a message on the voicemail at 468 005 239 – by using this method of notification, the notifier gives their consent to the making of an audio recording within the meaning of Section 19 of the Act.

Personal notification:

By arranging a meeting with the relevant person (meeting within 14 days of submitting a request to discuss the report via the contact telephone numbers or e-mail addresses of the relevant persons) – with the consent of the reporter, an audio recording will be made of the meeting; if consent is not given, a written record of the meeting will be made, faithfully capturing the essence of the oral report. The reporter has the opportunity to comment on the transcript of the recording or written record, and this comment will be attached to the transcript or record.

The whistleblower may also use other external reporting channels within the meaning of Section 7 of the Act to make a report.

Relevant persons:

Mgr. Tereza Hoffmanová, e-mail: th@ingtop.cz, tel.: 495 406 802
Petra Syrová, e-mail: syrova@ingtop.cz, tel.: 495 406 802

The designated persons handle all reports made. No one else has access to the reports. The contact details of the designated persons are not for the purpose of submitting reports, but only for arranging a meeting to submit a personal report.

The relevant person shall inform the notifier in writing of the receipt of the report within 7 days of its receipt.

The law stipulates a 30-day period for assessing the merits of the report and providing written notification of the results of this assessment. In factually or legally complex cases, this period may be extended by up to 30 days, but no more than twice.

The competent person shall assess whether the report complies with the law; if not, they shall inform the reporting person; if so, they shall further assess the merits of the report.

In the case of a justified report, the competent person shall propose measures to the obligated entity, i.e. the company, to prevent or remedy the unlawful situation. The company may adopt the proposed measures or create its own adequate measures – it shall inform the competent person of the measures taken, and the competent person shall then notify the reporting person.

If the report is not assessed as justified, the competent person shall inform the whistleblower of this conclusion in writing without undue delay and instruct them on their right to file a report with a public authority.

The relevant person is obliged to keep records of the reports received within the scope of the law:

a) date of receipt of the report,

b) the first name, surname, date of birth and contact address of the reporting person, or other information from which the identity of the reporting person can be deduced, if such information is known,

c) a summary of the content of the report and the identification of the person against whom the report was directed, if their identity is known,

d) the date of completion of the assessment of the merits of the report by the competent person or authorised employee and its outcome

Reports made through the internal reporting system and all related documents shall be retained by the relevant person for a period of 5 years from the date of receipt of the report.

Information on the processing of personal data in connection with the submission of a report

In connection with the submission of a report pursuant to the law through the company's internal reporting system, the reporter voluntarily provides personal data, which the company or relevant persons further process for the purpose of investigating or handling the reports submitted, and further for statistical purposes in anonymised form or to protect the rights of the company and third parties such as external collaborators, business partners, etc.

Categories of data processed

The following data is processed by the relevant person(s):

• date of receipt of the report,
• first name, surname, date of birth and contact address of the reporting person, or other data from which the identity of the reporting person can be deduced, if such data is known,
• summary of the content of the report and identification of the person against whom the report was made, if their identity is known,
• date of completion of the assessment of the merits of the report by the relevant person and its outcome,
• any related facts.

Recipients of personal data

The recipient of the whistleblower's personal data is the designated competent person who receives and handles individual reports. Some data (with the exception of the whistleblower's identification) may also be made available to authorised employees of the company or cooperating contractual partners to the extent necessary to fulfil the purpose of processing the report – but always on the basis of a contractual guarantee of the protection of the whistleblower's personal data.

However, only authorised persons have access to the records and documents related to the report and to the stored reports.

Personal data may also be disclosed to state authorities (e.g. courts, law enforcement authorities) on the basis of a legal obligation.

Period of personal data processing

Personal data is only stored for the period necessary, as required by law.

The relevant persons are obliged to store reports submitted through the internal reporting system and keep records of reports received for a period of 5 years from the date of receipt.

Rights of the data subject

The whistleblower has the following rights:

• Right of access to personal data
• Right to rectification or erasure
• Right to restriction of processing
• Right to data portability
• Right to object
• Right not to be subject to automated individual decision-making with legal or similar effects, including profiling
• Right to withdraw consent to the processing of personal data (if granted)

This directive shall enter into force on 1 December 2023.

In Týniště nad Orlicí on 1 December 2023

Michal Guldán

Company Executive

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