Investo reality s.r.o. has implemented an internal reporting system in accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers, and Act No. 253/2008 Coll., on Certain Measures Against Money Laundering and Financing of Terrorism. If a whistleblower has reasonable grounds to believe that Investo reality s.r.o. has committed an unlawful act, they are entitled to report such conduct.

What types of conduct can be reported?

The following types of conduct can be reported:
a) Conduct that constitutes a criminal offense,
b) Conduct that constitutes an administrative offense with a maximum fine of at least CZK 100,000,
c) Violations of Act No. 171/2023 Coll., on the Protection of Whistleblowers, or Act No. 253/2008 Coll., on Measures Against Money Laundering and Financing of Terrorism, or
d) Violations of other legal regulations or European Union legislation in areas such as:

  1. Financial services, statutory audits, and other verification services, financial products, and financial markets,
  2. Corporate income tax,
  3. Prevention of money laundering and terrorist financing,
  4. Consumer protection,
  5. Compliance with product requirements, including safety,
  6. Transportation safety and road traffic,
  7. Environmental protection,
  8. Food and feed safety, animal welfare, and animal health,
  9. Radiation protection and nuclear safety,
  10. Competition, public auctions, and public procurement,
  11. Public order and security, life, and health protection,
  12. Data protection, privacy, and security of electronic communication networks and information systems,
  13. Protection of the financial interests of the European Union, or
  14. Functioning of the internal market, including competition and state aid under EU law.

Who can submit a report?

The following individuals can submit a report:
a) An employee,
b) A person engaged by Investo reality s.r.o. in a non-employment relationship (in cases of AML law violations),
c) A person performing volunteer work, professional practice, or internships for Investo reality s.r.o.,
d) A whistleblower who has been or is in contact with Investo reality s.r.o. in connection with work or other similar activities under the Whistleblower Protection Act.

Investo reality s.r.o. excludes the acceptance of reports from other persons in accordance with § 9 para. 2(b), point 3 of Act No. 171/2023 Coll., on the Protection of Whistleblowers.

Who is the designated contact person?
Martin Hlavík
Email: info@investoreality.cz

How to submit a report?

Reports can be submitted:
a) By phone – to the number provided above,
b) Electronically – to the email address provided above,
c) By post – to the address provided above,
d) In person – within 14 days of requesting an appointment with the designated contact person,
e) To the Ministry of Justice,
f) To the Financial Analytical Office (in cases of AML law violations).

Investo reality s.r.o. informs whistleblowers that reports of violations related to AML law may also be submitted anonymously.

What must a report include?

A report must include:
a) Information about the possible unlawful conduct,
b) Details such as the whistleblower’s name, surname, and date of birth, or other data sufficient to establish the whistleblower’s identity (unless submitted anonymously).

Will the whistleblower receive feedback on the report?

The designated contact person will confirm receipt of the report in writing within 7 days, unless the whistleblower requests not to be notified, submits the report anonymously, or notification would reveal the identity of another person. The designated contact person must assess the report’s validity within 30 days of receipt and inform the whistleblower of the outcome. In legally or factually complex cases, this period can be extended by 30 days, up to twice.

Can the whistleblower be penalized for submitting a report?

Under the Whistleblower Protection Act, whistleblowers cannot be subjected to retaliatory measures. However, knowingly submitting a false report constitutes an offense punishable by a fine of up to CZK 50,000, and in such cases, whistleblower protection does not apply.