Reporting Unacceptable Conduct

At ČS NHQ, s.r.o., we are committed to open communication and trust. We do not tolerate unlawful, unethical, and unacceptable conduct, and therefore support tools leading to the detection of such behavior. Our goal is to create an environment that allows everyone to express their concerns without fear. As a key player in the construction of the new headquarters of Česká spořitelna, a.s. (hereinafter "ČS, a.s."), we strive to adhere to the highest standards in both construction and corporate governance and ethical conduct. We honor the ten basic principles in the areas of human rights, labor conditions, environment, and anti-corruption outlined in the UN Global Compact: Ten Principles | UN Global Compact.

Reporting unacceptable conduct is a crucial mechanism for us at ČS NHQ, s.r.o. to identify and address potential unlawful or unacceptable behavior.

What is unacceptable conduct?

any unlawful conduct,
violations of ESG (Environmental, Social, and Governance) rules,
violations of regulations (e.g., procurement rules, safety standards, workplace directives on construction sites),
any other conduct that can be considered unethical or unacceptable.

Who can file a report?

A reporter can be an employee of ČS NHQ, s.r.o. who is in an employment relationship (including job applicants, volunteers, interns, etc.) or another person who performs work or similar activities for ČS NHQ, s.r.o. (e.g., based on an assignment or contract for delivery, service, construction work, or similar fulfillment), as well as any employee of such a person or a person who performs work or similar activities for such a person. Reports can be submitted in one's own name or anonymously.

Unacceptable conduct can be reported:

Serious cases (concerning executives or members of the supervisory board of ČS NHQ, s.r.o., or involving damages exceeding EUR 3 million) should be reported through the channels established by Erste Group Bank AG:

online: Erste Integrity Line Platform
by phone: +43 681 20750821,
via postal service to the address: OU 0196 0985 Non-Financial Risk Management, Am Belvedere 1, A-1100 Vienna,
personally upon request.

Other cases should be reported through the channels established by ČS, a.s:

online: Nenech to být (NNTB),
by phone: +420 705 573 017,
by email: oznameniwb@csas.cz,
via postal service to the address: ČS, a.s., unit 6800 Compliance, WBO FSČS – do not open, Olbrachtova 1929/62, 140 00 Prague 4,
personally upon request.

All information will be handled with maximum confidentiality and professionalism. Your identity as the whistleblower, as well as the information provided, will be known only to the assigned person handling the report.

What is whistleblowing?

Whistleblowing is the English term for reporting unlawful conduct (one of the categories of unacceptable conduct), which is regulated in the Czech Republic by Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (hereinafter "the Act"), which grants whistleblowers an increased level of protection.

To qualify as whistleblowing, the report must contain information about possible unlawful conduct that:

has the characteristics of any criminal offense (e.g., theft, embezzlement, fraud, breach of duty in managing foreign property, bribery, damage and endangerment of the environment, violation of competition rules),
has the characteristics of an offense for which the law prescribes a fine with an upper limit of at least 100,000 CZK,
violates the Act,
violates another legal regulation or European Union regulation (according to § 2, paragraph 1, letter d) of the Act).

In addition to the internal reporting system described above, the Act also allows for other reporting methods:

Through the Ministry of Justice's reporting system, available at: https://oznamovatel.justice.cz/,
Through publication, for example in the media (only in cases listed in § 7 paragraph 1, letter c) of the Act).

ČS NHQ, s.r.o. will not take any negative (retaliatory) measures against the reporter in connection with the submission of a report, such as termination of employment, reduction of salary or other disadvantage, termination of permanent cooperation, reduction of remuneration.

How is the report handled?

We will confirm receipt of the report in writing to the reporter (unless the report handler explicitly requests not to be notified of the receipt of the report, the report was made anonymously and there is no way to respond, or it is clear that notifying of the receipt of the report would reveal the identity of the reporter to another person),
We will investigate the circumstances of the reported conduct and propose measures to prevent the continuation of this conduct,
We will inform the reporter of the outcome of the investigation (if the report was not made anonymously and we are able to contact the reporter).

Important information before submitting

The reporter should have a valid reason to believe that the facts being reported or disclosed are authentic and true, given the circumstances and information available at the time of the report. It is therefore not permissible to report knowingly false facts. The reporter may face consequences for such conduct from ČS NHQ, s.r.o., as well as from the injured party or state authorities.

When reporting unacceptable conduct, it is very important to provide as much information as possible (e.g., specifying the time and place of the event, the persons involved, providing specific documents if available, and describing all other relevant circumstances of the case), which will enable the handler to conduct an effective investigation and take prompt and effective corrective action.

Together, let's protect the integrity of our organization. Your voices are important, and we want to hear them.