Rules for Reporting Suspicions of Possible Unlawful Conduct at ALVA TOUR s.r.o.

1. Introductory Provisions

1.1.
ALVA TOUR s.r.o., Company ID No. 49684167, with its registered office at Sokolovská 146/70, Karlín, 186 00 Prague 8, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Insert 23315 (hereinafter referred to as “ALVA TOUR s.r.o.”), issues these Rules for Reporting Suspicions of Possible Unlawful Conduct at ALVA TOUR s.r.o. (hereinafter referred to as the “Rules”), which further develop the rules for reporting suspected unlawful conduct set out in the Whistleblower Protection Directive of ALVA TOUR s.r.o., as amended and in force.
1.2.
At ALVA TOUR s.r.o., we are committed to upholding the company’s values, legal regulations, internal policies and best practices. To support this, we have established a system that enables unlawful conduct to be reported so that it can be reviewed and, where appropriate, remedied in a timely manner.

2. Whistleblower

2.1.
A whistleblower may be any natural person who has obtained information about unlawful conduct in connection with work or other similar activity at ALVA TOUR s.r.o. (hereinafter referred to as the “Whistleblower”). This includes, in particular, current, former or prospective employees, job applicants, contractors, shareholders, members of the company’s bodies, suppliers and subcontractors.
2.2.
If a Whistleblower reports suspected unlawful conduct, ALVA TOUR s.r.o. declares that it will not take any retaliatory measures against the Whistleblower or persons close to them in connection with the report.
2.3.
Retaliatory measure means any act related to the Whistleblower’s work or other similar activity that is triggered by the report and may cause harm to the Whistleblower.
2.4.
A report may also be submitted anonymously. In such a case, ALVA TOUR s.r.o. declares that it will not seek to identify the Whistleblower.

3. Designated Person

3.1.
Mgr. Alice Baumruková Kotylová has been appointed to receive and assess reports concerning possible unlawful conduct within ALVA TOUR s.r.o. (hereinafter referred to as the “Designated Person”).
3.2.
If the Designated Person finds the report to be well-founded, they will propose corrective measures or a course of action to prevent the unlawful situation.
3.3.
In performing their duties under these Rules, the Designated Person acts impartially and is obliged to maintain confidentiality regarding all facts learned in the course of their role.
3.4.
The Designated Person shall maintain strict confidentiality regarding the identity of the Whistleblower, the personal data of other natural persons, and the information contained in the report.
3.5.
ALVA TOUR s.r.o. declares that the Designated Person will not be penalised in any way for the proper performance of their duties.

4. Reports and Procedure after Receipt of a Report

4.1.
A report may be submitted:
• by email to: schrankaduvery@alvatour.cz
• by telephone at: 724 122 845 / The call will be recorded unless the Whistleblower does not consent to an audio recording; in that case, the Designated Person will make a written record of the call. The Whistleblower is entitled to review, correct and approve the record by signature.
• in writing by letter marked “Whistleblower Protection – for the attention of the Designated Person” sent to: ALVA TOUR s.r.o., Sokolovská 146/70, Karlín, 186 00 Prague 8
• in person to the Designated Person / The Designated Person must allow the Whistleblower a personal meeting within 14 days of receiving the request. An audio recording will be made of the meeting. If the Whistleblower does not consent to a recording, the Designated Person will make a written record of the meeting instead. In that case, the Whistleblower is entitled to review, correct and approve the record by signature.
4.2.
The Designated Person will acknowledge receipt of a written report within 7 days of receiving it.
4.3.
The Designated Person will inform the Whistleblower of the outcome of the assessment within 30 days of receiving the report. In legally or factually complex cases, this period may be extended by up to a further 30 days.
4.4.
If the assessment shows that the report was unfounded, this does not mean that the Whistleblower acted improperly, and the Whistleblower will not be sanctioned in any way for having made the report.
4.5.
However, the Whistleblower must not knowingly make false or inaccurate reports, nor misuse these Rules to harass or intimidate any person or to obtain personal advantages. Knowingly false reports may be sanctioned under Act No. 171/2023 Coll., on the Protection of Whistleblowers.

5. Alternative Submission of a Report

5.1.
A report may also be submitted to the Ministry of Justice, including in cases where the Whistleblower is unsure whether the facts identified constitute unlawful conduct.

Contacts for the external reporting system operated by the Ministry of Justice:
telephone.: 221 997 840, email: oznamovatel@msp.justice.cz, website: https://oznamovatel.justice.cz/chci-podat-oznameni/.

6. Final Provisions

6.1.
All employees, managers and members of the bodies of ALVA TOUR s.r.o. are obliged to comply with the above Rules. A breach of these Rules may result in disciplinary measures.
6.2.
These Rules will be published on the website of ALVA TOUR s.r.o.
6.3.
These Rules enter into force on 1 December 2023.
In Prague, dated 1 December 2023.

ALVA TOUR s.r.o.
Lukáš Chlumský, Managing Director

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