To establish a secure, innovative, and effective framework for reporting, investigating, and addressing misconduct within Walleexer s.r.o. ("the Company"), ensuring the highest standards of transparency, protection, and trust.
This policy applies to all employees (full-time, part-time, temporary), officers, contractors, agents, consultants, and any third party acting on behalf of the Company.
Misconduct: Any act or omission that may cause financial loss, reputational damage, regulatory breach, or harm to the Company, clients, or third parties (e.g., corruption, fraud, money laundering, data breaches, ESG violations, AI-related risks).
Whistleblower: An individual reporting suspected or actual misconduct under this policy.
Protected Disclosure: A good-faith report about potential or actual wrongdoing.
Confidentiality: The obligation to protect the identity and personal data of the whistleblower, except as legally required.
Retaliation: Any adverse action taken against a whistleblower as a result of their disclosure (e.g., dismissal, demotion, harassment).
Legal Compliance: Adherence to EU Directive 2019/1937, Czech legislation, GDPR, AML/CFT, and corporate governance regulations.
Confidentiality: Maximum protection of whistleblower identity and data.
Impartiality: Objective handling of all reports by the Compliance Committee, including external experts where appropriate.
No Retaliation: Zero tolerance for any adverse actions against whistleblowers.
Transparency: Clear communication about procedures, status, and outcomes of reports, within legal limits.
Continuous Improvement: Regular assessment and enhancement of the policy based on feedback and new risks.
Initial Assessment: The Compliance Committee evaluates the credibility and scope of the report within 14 calendar days, using AI tools to identify trends and systemic risks.
Formal Investigation: If warranted, a full investigation begins and concludes within 3 months (extensions permitted with notice to the whistleblower).
External Experts: Complex cases may involve independent experts or the external ombudsman.
Whistleblower Updates: The whistleblower receives regular updates on the investigation's progress and outcome, as permitted by law.
Outcome & Actions: Findings are shared with relevant parties; corrective and/or disciplinary measures are implemented. The whistleblower is informed of outcomes as allowed by law.
No Retaliation: Strict prohibition of dismissal, demotion, harassment, or any adverse action against whistleblowers.
Examples of Retaliation: Detailed in a separate appendix.
Urgent Response Mechanism: Emergency review and temporary protection are provided if retaliation is reported.
Reverse Burden of Proof: The Company must prove that any negative action is unrelated to whistleblowing.
Support Services: Free psychological support and access to anonymous peer support groups are available.
Compliance Committee: Manages reports, conducts investigations, enforces policy, and includes independent experts or employee representatives.
Senior Management: Ensures policy awareness, upholds non-retaliation, and supports committee independence; responsible for fostering an open culture.
Ethics Ambassadors: Designated in each department to provide advice and support.
All Employees/Third Parties: Required to report suspected misconduct promptly and in good faith.
Mandatory Training: Annual interactive training with practical case studies and updates on new risks (AI, ESG, cybersecurity).
FAQ and Guidelines: Available on the internal portal.
Onboarding: Policy explained during new hire orientation.
Regular Surveys: Anonymous surveys to assess awareness and trust in the system.
Publicizing Cases: Anonymized examples of resolved cases and actions taken are published for staff education.
Management Commitment: Leadership regularly reaffirms support for whistleblowers and the policy.
Idea Hackathons: Internal hackathons or idea contests to improve the whistleblowing system.
Regular Review: At least annually, after significant incidents, or legal/regulatory changes.
Continuous Improvement: Policy is updated based on feedback, new risks, and audit results.
Approval: All amendments approved by the Board of Directors.
Approved by the Board of Directors of Walleexer s.r.o.