PRINCIPLES OF WHISTLEBLOWER PROTECTION (WHISTLEBLOWING)

dated January 1, 2026

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  1. INTRODUCTORY PROVISIONS
    1. Contents of the principles
      1. In accordance with Section 9(2)(b) and Section 10 of Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (the "Act"), these principles set out the following information:
      2. methods of submitting reports through the internal reporting system of Ambit advokáti s.r.o. (the "obligated entity") and through the Ministry of Justice of the Czech Republic (the "ministry"),
      3. conditions for the receipt and processing of reports by the obligated entity, 
      4. identification of the competent person (the "competent person"), including contact details,
      5. definition of the group of persons from whom the obligated entity accepts reports within the meaning of the Act.
      6. Any conduct that meets the criteria for unlawful conduct under Act No. 253/2008 Coll., on certain measures against the legalization of proceeds from crime and terrorist financing, as amended (the "AML Act"), shall always be reported in accordance with the procedure set out in the AML Act to the entities specified therein.
    2. Scope of reporting
      1. The obligated entity, through the competent person, receives and processes reports made by an employee of the obligated entity or a person who performs voluntary work, professional practice or an internship at the obligated entity (the "whistleblower"). The obligated entity does not exclude the receipt of reports from other persons who are active for the obligated entity in a manner other than in a basic employment relationship.
      2. A report is considered to be a communication containing information about possible unlawful conduct that has occurred or is about to occur at the obligated entity or at a person with whom the whistleblower has been or is in contact in connection with the performance of employment, volunteer work, professional practice, or internship at the obligated entity, and which has the characteristics of a criminal offense or misdemeanour for which the law stipulates a fine of at least CZK 100,000, violates the Act or other 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, shipping, and road traffic safety, 
  7. environmental protection, 
  8. food and feed safety and animal protection and health, 
  9. radiation protection and nuclear safety, 
  10. economic 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. the functioning of the internal market, including the protection of competition and state aid under European Union law. 
  1. Except in cases where the whistleblower is known to the competent person, the report must contain the first name, surname, and date of birth, or other information enabling the identification of the whistleblower.
  2. The report must not violate:
  1. the duty of confidentiality in the performance of the activities of a lawyer, trainee lawyer, and employee of the company through which the lawyer practices law as a partner under the law governing the practice of law, or another person who participates in the provision of legal services within such a company, 
  2. duty of confidentiality when providing legal assistance in proceedings before a court or other public authority.
  1. Competent person 
    1. The obligated entity has appointed a competent person and a substitute competent person. Unless otherwise specified in these principles, all provisions concerning the competent person shall apply mutatis mutandis to the substitute competent person.
    2. The competent person appointed is JUDr. Tomáš Ditrych, LL.M., Ph.D., tel. +420 775 950 599, email: tomas.ditrych@ambit.law, has been appointed as the competent person.
    3. The substitute competent person appointed is JUDr. Ing. Jaroslav Menčík, LL.M., Ph.D., tel. +420 777 805 790, email: jaroslav.mencik@ambit.law, has been appointed as the substitute responsible person.
    4. The competent person receives and processes reports. The substitute competent person receives and processes reports in cases where the competent person is unable to do so, or in the circumstances specified in paragraph 1.3.5.
    5. If there is any doubt about the impartiality of the competent person, they shall forward the report to the substitute competent person for handling, and if the report cannot be forwarded to the substitute competent person, the competent person shall inform the reporter of this fact and instruct them on the possibility of submitting a report through an external reporting system.
  1. PROCEDURE FOR SUBMITTING A REPORT 
    1. Submitting a report 
      1. The form in Appendix 1 may be used to submit a report. 
      2. The competent person shall receive reports through the contact channels specified in 1.3.2 and 1.3.3. Reports may also be made in person and/or anonymously to the designated mailbox at the registered office of the obligated entity. Reports may also be submitted to the ministry using the form available at https://oznamovatel.justice.cz. 
    2. Evaluation of reports
      1. The competent person shall immediately notify the whistleblower in writing of the receipt of the report, but no later than 7 days from the date of receipt of the report. The competent person shall not do so if the identity of the whistleblower would be disclosed or if the whistleblower so requests.
      2. After evaluation, the competent person shall inform the whistleblower of the result of such assessment within 30 days of the date of receipt of the report. In factually or legally complex cases, this period may be extended by up to 30 days, but no more than twice. 
      3. In the event that certain necessary information or data is missing, the competent person shall request the whistleblower to provide it. In such a case, the time limit referred to in paragraph 2.2.2 shall only start to run from the date on which the competent person receives the requested additional information or data.
      4. If, when assessing the validity of the report, the competent person concludes that it is not a report within the meaning of the law, they shall inform the reporter without undue delay and instruct the reporter on their right to contact the competent public authority. Otherwise, the competent person shall, without undue delay, propose to the obligated entity appropriate measures to prevent or remedy the unlawful situation, while maintaining the confidentiality of the identity of the whistleblower and the person referred to in paragraph 3.1.2.
      5. The obligated entity shall take the measures proposed by the competent person or other appropriate measures. The competent person shall immediately notify the whistleblower thereof.
    3. Records of reports
      1. The competent person shall keep electronic records of data on reports received, which shall include
  1. the date of receipt of the report, 
  2. the first name, last name, date of birth, and contact address of the whistleblower or other information from which the identity of the whistleblower can be deduced, if known,
  3. a summary of the content of the report and identification of the person concerned, if their identity is known, 
  4. the date of completion of the assessment of the merits of the report by the competent person and its outcome, 
  5. proposed and adopted preventive or corrective measures. 
  1. The competent person shall keep the report and related documents for a period of 5 years from the date of receipt of the report.
  2. Access to the records, reports, and documents retained pursuant to paragraph 2.3.2 shall be restricted to the competent person.
  1. Processing of personal data 
    1. The obligation to assess the impact on personal data protection shall not apply to the processing of personal data in connection with the report.
    2. The processing of personal data in connection with the report is carried out on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR") , taking into account the need to maintain the confidentiality of the whistleblower's identity.
  1. PROTECTION OF THE WHISTLEBLOWER AND THE RIGHTS AND OBLIGATIONS OF THE COMPETENT PERSON AND OTHER PERSONS
    1. Protection of the whistleblower and other persons
      1. Retaliatory measures are considered to be actions or omissions that may cause harm to the whistleblower or a person referred to in paragraph 3.1.2. Retaliatory measures include, in particular:
  1. termination of employment or non-renewal of employment or a working relationship based on a contract for work or a contract for services,
  2. reduction of wages, salary, or remuneration, or non-granting of a personal allowance,
  3. transfer or reassignment to another job, 
  4. performance evaluation or work assessment, 
  5. denial of professional development, 
  6. change in working hours, 
  7. requiring a medical assessment or occupational health examination, 
  8. termination or withdrawal from the contract, or 
  9. interference with the right to protection of personality. 
  1. No retaliatory measures may be taken against the whistleblower or
  1. a person who provided assistance in gathering information that is the subject of the report, in filing the report, or in assessing its merits, 
  2. a person who is close to the whistleblower, 
  3. a person who is a colleague of the whistleblower. 
  4. or other persons specified by law.
  1. Rights and obligations of the competent person and the obligated entity 
    1. When assessing the validity of a report, the competent person is entitled to request information, make copies, transcripts, extracts, and other audiovisual recordings. 
    2. The competent person is entitled to require persons performing work or other similar activities for the obligated entity to prepare, within a reasonable time, a written statement on the factual issues related to the report.
    3. The competent person shall perform their duties personally, impartially, and confidentially. 
    4. The competent person may disclose the identity of the person against whom the report is directed to the necessary circle of persons for the purpose of investigating the information contained in the report or proposing or imposing preventive or corrective measures.
    5. The competent person shall submit to the obligated entity an annual written report on their activities for the past calendar year, which shall include:
      1. the total number of admissible reports, 
      2. the number of reports that were forwarded to the competent public authority, 
      3. the number of ongoing investigations, 
      4. the number of completed investigations, 
    6. the number of reports for which the information contained therein could not be investigated, including the reasons why, 
    7. number of reports meeting the parameters set out in paragraph 1.2.2, 
      1. identified deficiencies, proposed preventive or corrective measures, and preventive or corrective measures taken. 
    8. The obligated entity shall publish the report pursuant to paragraph 3.2.5 in a manner allowing remote access within 15 days of its submission by the competent person.

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Annex No. 1 

Form for submitting a report

 

 

First name and surname:  

 

 

Date of birth:  

 

 

 

Other information from which the identity of the whistleblower can be deduced:  

 

 

Email or other delivery address: 

 

 

Phone:  

 

 

Working relationship with the obligated entity: 

 

Qualification of the reported possible unlawful conduct within the meaning of Section 2(1) of Act No. 171/2023 Coll., on the protection of whistleblowers. Reported conduct: 

 

 

 

 

 

 

Attachments:  

 

 

 

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