Whistleblowing

Information on whistleblowing

V This document sets out the options for making a whistleblowing report which may involve Direct Fidoo Payments s.r.o. (hereinafter referred to as “Company“171/2023 Coll., on the protection of whistleblowers, and Act No. 253/2008 Coll., on certain measures against the legalization of the proceeds of crime and the financing of terrorism (hereinafter referred to as “Legislation“).

Who can submit a notification

Only natural persons in relation to the Company:

• employee in basic employment relationship,
• a person doing voluntary work, work experience or an internship, or
• a candidate for a job or other similar activity in the Company

For other persons, the Company excludes the possibility to submit a notification through the established notification system.

What actions can be reported

Notification may be made of possible violations that have occurred or are about to occur at the Company and which:

1. has the elements of a crime,
2. has the characteristics of a misdemeanour for which the law provides for a fine with an upper limit of at least 100 000 CZK,
3. violates the Laws or
4. violates another legal regulation of the Czech Republic or a regulation of the European Union in the area:

• financial services, due diligence and other assurance services, financial products and financial markets,
• tax on corporate income,
• Prevention of the laundering of the proceeds of crime and terrorist financing,
• consumer protection,
• environmental protection,
• competition, public auctions and public procurement,
• Protection of internal order and safety, life and health,
• protection of personal data, privacy and security of electronic communications networks and information systems,
• the protection of the financial interests of the European Union, or
• the functioning of the internal market, including the protection of competition and state aid under European Union law, and possibly others.

How to make a notification

The whistleblower has the right to file a notification with the designated competent person of the Company: Ing. Martina Janiuková, in the following ways.

• electronically to the email address whistleblowing@fidoo.com, where the subject of the notification must be marked “Confidential” and intended for the hands of the relevant person only;
• in writing by letter addressed expressly in the person’s own hands to the address

Campus Port7

Pod Dráhou 1636/1

170 00 Prague 7 – Holešovice.

The sealed envelope must be explicitly marked with the word DO NOT OPEN – CONFIDENTIAL.

In such a case, only the competent person may open the envelope;

• by phone at tel. the number of the relevant person +420 604 594 177, at on weekdays between 8 am and 4 pm;
• in person , by prior electronic telephone arrangement with the relevant person, on weekdays between 8 a.m. and 4 p.m.

The competent person shall, with the consent of the whistleblower, make an audio recording or transcript of the oral notification and allow the whistleblower to comment on the recording or transcript of the audio recording.

The whistleblower can also submit a notification through the external notification system set up by the Ministry of Justice: https://oznamovatel.justice.cz/chci-podat-oznameni/. However, the whistleblower is not entitled to submit notifications of facts relating to violations of Act No.  253/2008 Coll., on Certain Measures against the Legalization of Proceeds of Crime and the Financing of Terrorism. Whistleblowers may contact the Financial Analysis Office (FAO) in cases of notifications concerning violations of the Act: Notification of suspicious trade | FAÚ (gov.cz)

The notification can also be made anonymously. In case the whistleblower wants to be informed about the progress and outcome of the solution, it is necessary that he/she leaves his/her contact details.

How the notification will be handled

The relevant person shall notify the notifier of receipt of the notification within 7 calendar days of receipt, unless the notifier has specifically requested the relevant person not to notify him or her of receipt of the notification or it is clear that notification of receipt of the notification would disclose the identity of the notifier to another person.

The competent person shall assess the validity of the notification and notify the notifier in writing of the results of the assessment within 30 calendar days of receipt of the notification. In cases of factual or legal complexity, this period may be extended by up to 30 calendar days, but not more than twice, of which the notifier will be informed in advance.

If, in assessing the reasonableness of a notification, the competent person finds that it is not a notification under the Legislation, he or she shall notify the notifier in writing without undue delay.

The notifier is obliged to provide the authorised person with assistance for the investigation of the notification. If the notification is deemed to be justified, the relevant person of the Company shall propose measures to prevent or remedy the infringement. The Company shall promptly notify the person concerned of the action taken, who shall inform the whistleblower in writing without undue delay.

If the notification is not found to be substantiated, the competent person shall without undue delay inform the notifier in writing that, on the basis of the facts stated in the notification and the circumstances known to him, he does not find that the offence is suspected or that the notification is based on false information. The competent person shall also inform the whistleblower of his right to file a report with the Ministry of Justice.

Guarantee of protection for the whistleblower

The Company undertakes to ensure the continued protection and confidentiality of the information contained in the notification to the whistleblower and other affected persons. The protection consists in particular in the prohibition of retaliation against the whistleblower, including threats or attempts at retaliation.

The internal notification system can only be accessed by an authorised competent person of the Company. The identity of the whistleblower will not be disclosed to anyone else without their consent.

If a whistleblower knowingly makes a false report, he/she exposes himself/herself to penalties.