Whistleblowing – INTERNAL REPORTING CHANNEL

In accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers (“Whistleblowers Protection Act”), Outreach Czech s.r.o., with its registered address at Plynární 1617/10, Holešovice, 170 00 Prague 7, ID No: 090 37 641, registered with the Commercial Register maintained by the Municipal Court in Prague, File No. C 329587 (“Outreach”), operates an internal reporting channel that provides confidential means of communication to report possible wrongdoings and ensure that the reports made by reporting persons are investigated in a transparent, efficient, and objective manner and that Outreach takes appropriate preventive or remedial measures.

What can be reported?

The report must contain information about a possible breach that has occurred or is about to occur at Outreach and that: 

1. shows signs of a criminal offence; 
2. shows signs of an administrative offence with the maximum fine of at least CZK 100,000; 
3. breaches the Whistleblowers Protection Act; or 
4. violates EU legal regulations or other legal regulations in the following areas:
   1. financial services, mandatory audit and other assurance 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 product safety,
   6. transport, traffic, and road safety,
   7. protection of the environment,
   8. food and feed safety and protection of animals and their health,
   9. radiation protection and nuclear safety,
   10. competition law, 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 EU, or
   14. the functioning of the internal market, including the protection of competition and state aid under the EU law.

Who can make a report?

Individuals who perform/performed work or other similar activity for Outreach or who are/were in work-related or business-related contact with Outreach and who fall in any of these categories: (i) employees, (ii) volunteers, (iii) interns; (iv) self-employed persons, including candidates for these roles (the “Whistleblowers”). 

All other persons are excluded from using the internal reporting channel operated by Outreach even if they perform work or other similar activity for Outreach or are in work/business related contact with Outreach. Namely, the following categories of potential whistleblowers are excluded: (i) shareholders, (ii) members of Outreach’s bodies, (iii) persons who perform tasks within the framework of Outreach’s activities, in its interest, on its behalf or on its account, (iv) trust fund administrators, and (v) persons exercising rights and obligations under a contract for the provision of supplies, services, construction works or other similar performance (suppliers and/or their staff).

How to make a report?

Reports must be submitted to any or all of the following persons:

1. Klára Štouračová, CZ HRBP;
2. Lucie Michalíková, CZ HR Specialist;
3. Danielle Eelkema, VP, People Experience;
4. Maggie Anthoney, Legal Counsel

(the “Whistleblowing Officers”).

Reports may be submitted via the internal reporting channel:

1. in writing by email to the e-mail address: whistleblowingcz@outreach.io; 
2. orally by calling the following telephone numbers of the Whistleblowing Officer(s):
   1. + 420 739 071 581 (primary line);
   2. + 420 773 736 637 (secondary line – to be used if the primary line does not answer or is unavailable).

The telephone lines are operated on working days from 9:00 am to 5:00 pm. Outside these hours, Whistleblowers can make reports in writing, or the Whistleblowing Officers may call a Whistleblower back in reaction to the missed call;

1. upon the Whistleblower’s request, during a personal meeting with a Whistleblowing Officer – please arrange for the meeting in advance by email or by calling the Whistleblowing Officer(s).

Reports must contain the name, surname, and date of birth of the Whistleblower, or other data from which the identity of the Whistleblower can be deduced. Outreach does not accept anonymous reports.

Outreach encourages Whistleblowers to prioritise the internal reporting channel to ensure prompt and effective handling of the report and proper follow-up by the company. Whistleblowers may nevertheless also use the external reporting system of the Ministry of Justice (Chci podat oznámení – veřejnost – Oznamovatel (justice.cz))

Protection of Whistleblowers

A Whistleblower who makes a report in good faith (i.e. having reasonable grounds to believe that the facts reported are true, given the circumstances and the information available to them at the time of the report) are entitled to protection under the Whistleblowers Protection Act. Their identity will be kept confidential and Outreach will not tolerate any retaliation against them. However, knowingly false allegations (e.g. with malicious intent to harm another employee) are in violation of the Whistleblowers Protection Act and will be considered misconduct and may result in disciplinary, civil, administrative, or criminal action including a financial penalty of up to CZK 50,000.

Whistleblowers must not commit a criminal offence when obtaining information and evidence to make a report.

For information about the protection of personal data of the Whistleblowers, please reach out to the Whistleblowing Officer(s).