Protection of persons reporting breaches of Union law

RAVAK a.s. becomes, due to the so-called direct applicability of the Directive of the European Parliament and of the Council (EU) 2019/1937 of 23.10.2019 on the protection of persons reporting breaches of Union law, from 1.4.2022 a mandatory subject to establish a so-called internal reporting system enabling in particular to receive from the below specified range of natural persons reports on actions against EU law, to handle them, to protect the identity of the reporters and other persons, to protect the information stated in the report and to communicate with the reporters. The main aim of the protection of reporters in this area is to enable the detection of illegal actions taking place at the workplace or during the performance of work (or similar) activity or in connection with it, about which employees and other natural persons in a similar position under normal circumstances do not inform the employer or the relevant state authorities, especially for fear of losing their job or other punishment.

Natural persons who may, according to the above-mentioned Directive of the EP and the Council (EU), report possible illegal activities:

• employees of the mandatory subject (i.e. persons performing work for RAVAK a.s. based on an employment contract or agreements on work performed outside of employment),
• persons in a service relationship to the mandatory subject,
• persons providing supplies of products or services for the mandatory subject (so-called self-employed persons),
• persons performing the function of a member of a legal entity's body, who is elected, appointed or otherwise called to the function, when at the same time the mentioned legal entity is at least partly established by the mandatory subject or provides supplies of products or services, construction works or other similar performance for the mandatory subject,
• persons administering a trust fund,
• persons performing volunteer activities,
• persons performing professional practice or internship at the mandatory subject,
• persons applying for a job or similar activity at the mandatory subject.

The above-mentioned natural persons are entitled to report illegal actions (breaches of Union law) concerning at least some of these areas:

• public procurement,
• financial services, products and markets and prevention of money laundering and terrorist financing,
• product safety and compliance with regulations,
• transport safety,
• environmental protection,
• radiation protection and nuclear safety,
• food and feed safety, animal health and welfare,
• public health,
• consumer protection,
• protection of privacy and personal data and security of networks and information systems,
• financial interests of the Union according to Article 325 TFEU and further specified in the relevant Union measures and breaches concerning the internal market according to Art. 26 para. 2 of the Treaty on the Functioning of the EU, including breaches of EU rules on competition and state aid, as well as breaches concerning the internal market in connection with actions that violate the rules concerning corporate income tax, or with mechanisms whose purpose is to obtain a tax advantage that frustrates the object or purpose of the relevant law in the field of corporate income tax.

Note: The complete list of legal regulations falling within the material jurisdiction of the Directive of the European Parliament and of the Council (EU) 2019/1937 of 23.10.2019 on the protection of persons reporting breaches of Union law has been published on the website of the Ministry of Justice (www.justice.cz) since 17. 12. 2021 and will be continuously updated.

The person designated to receive, examine and further handle the reports is:
Tomáš Doul, Keystone Company a.s., tel.: 608 183 080, e-mail: info at ksco.cz