The company GoPay Czech, odštěpný závod zahraniční právnické osoby Worldline NV, Kingdom of Belgium, with its registered office at Senovažné nám. 1736, 370 01 České Budějovice, company registration number: 221 774 69, registered in the Commercial Register maintained by the Regional Court in České Budějovice, Section A, Insert 11596 („GoPay“) has established an internal reporting system in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers.
WHAT CAN BE REPORTED?
Unlawful conduct that has occurred or is to occur at GOPAY and which the whistleblower has learned about, even indirectly, in connection with the performance of their work or other similar activity within the meaning of Section 2(3) of Act No. 171/2023 Coll., on the protection of whistleblowers, can be reported. The conduct reported can be any alleged breach of the Worldline Code of Ethics or of the legislation of the Czech Republic or other applicable local laws and regulations, and other wrongdoing.
To clarify what can be reported, we give the following list of examples, which is indicative only:
Breaches of European internal market law (in particular in the area of the legal regulation of taxes, tax incentives and unfair competition);
Breaches affecting the financial interests of the European Union;
Breaches of environmental protection;
Breaches of animal welfare and health;
Harm to public health;
Breaches of anti-money laundering and counter-terrorist financing rules;
Breaches of product conformity and of user and consumer safety systems;
Compromising personal data protection and privacy systems; accepting and/or offering bribes, corruption, bribery, acting in personal interest, maladministration;
Organising unfair competition, breaching competition protection rules;
Misuse of confidential information for personal purposes (insider trading);
Committing theft, fraud, misappropriation of company property;
Inappropriate behaviour such as discrimination, bullying or harassment;
Breaches of human rights, including slavery and exploitative practices;
Acting contrary to the company's interests;
Money laundering or the financing of terrorism;
Receiving or handling the proceeds of crime;
Making false statements (e.g. financial ones);
Trading with parties subject to embargoes or sanctions;
Concealing negligent, fraudulent or other criminal activities; c
reating or ignoring a risk to health, safety or the environment;
and breaches of national, international and European legislation.
Reporting confidential information is excluded, in particular information relating to national security, information covered by legal professional privilege and information covered by medical confidentiality.
WHO CAN MAKE A REPORT?
Reports can be made by persons who perform or have performed work or other similar activity for GoPay, in particular employees, job applicants, persons performing work for GoPay on a basis other than an employment relationship, and business partners and subcontractors.
A report can also be made anonymously.
HOW CAN A REPORT BE MADE?
A report can be made in writing via https://worldline.integrityline.org, or orally to the designated persons listed below. If you want to make a report in person, the designated person is obliged to receive the report within 14 days of the day you requested to make it in person.
WHAT IS THE REPORTING SYSTEM NOT FOR?
The internal reporting system is not for submitting questions to the company or as a means of expressing opinions about persons employed by or cooperating with GoPay. Please also bear in mind that knowingly making a false report is an offence that can be punished by a fine of up to CZK 50,000.
WHAT MUST A REPORT CONTAIN?
A report must contain at least:
Identification of the person the report concerns
Identification, in as much detail as possible, of the breach of the rules it concerns
A report may also contain:
Identification of the whistleblower
The whistleblower's contact details
Further supporting materials and evidence
HOW IS A REPORT HANDLED ONCE IT HAS BEEN MADE?
Once a report has been made using the internal reporting system, we are obliged to inform you of this within 7 days of receiving it. This does not apply if you expressly request not to be informed that the report has been received, or if doing so could reveal your identity, or if the report does not state your identity or a way of contacting you. A period of 30 days is then set for assessing the report, which can be extended twice because of the factual or legal complexity of the assessment. We will inform you of any extension, and the above applies mutatis mutandis.
If the designated person needs it, they can ask the whistleblower, where their identity is known, to supplement or clarify the information given in the report. The whistleblower is contacted only on condition that this will not reveal their identity.
In the circumstances set out above we will inform you of the results of the assessment of the report without undue delay. We will also inform you of any further steps and of the corrective measures as soon as they are adopted.
You also have the option of using the external reporting system maintained by the Ministry of Justice: https://oznamovatel.justice.cz/chci-podat-oznameni/. That page of the Ministry of Justice also gives the contact details of the Ministry of Justice's designated person. Only reports within the meaning of Section 2 of Act No. 171/2023 Coll., on the protection of whistleblowers, can be made through the external reporting system, where the range of unlawful conduct that can be reported is defined more narrowly than within GOPAY's internal reporting system.
WHO IS THE PERSON DESIGNATED TO RECEIVE AND ASSESS REPORTS?
The persons designated to receive and assess reports are Zbyněk Eiselt, telephone +420 602 468 240, address for electronic written submissions https://worldline.integrityline.org, postal address: 370 01 Litvínovice 286, Czech Republic, which must be marked “do not open, whistleblowing”, and Catherine Bioul, telephone +32 474 43 65 79, address for electronic written submissions https://worldline.integrityline.org, postal address: Desiré Van Hoomissenstraat 40, 2880 Bornem, Kingdom of Belgium, which must be marked “do not open, whistleblowing”.