Ethics & Whistleblowing

Whistleblowing

Within the meaning of the Czech Act on the Protection of Whistleblowers (“the Act”), EmbedIT s.r.o. (“EmbedIT”) has established the following internal reporting system for whistleblowers and appointed the persons set out below who are responsible for receiving and dealing with the notifications ("Nominated Persons”).

Who can report?

Whistleblowers can be persons who are employees of EmbedIT, or execute similar activity for EmbedIT, including members of corporate bodies, job applicants, trainees, or former employees. In line with Section 9 (2)(a) of the Act, submission of notification by persons exercising rights and obligations under a contract for the provision of supplies, services, construction works, or other similar performances (i.e. activities mentioned in Section 2 (3)(j) of the Act) are excluded.

What can be reported?

Notifications may relate to illegal conduct of which the whistleblower became aware in connection with the performance of his/her work for EmbedIT and which:

  • has elements of a criminal offence,

  • has elements of administrative offense for which law stipulates a fine of at least CZK 100,000,

  • violates the Act itself, or

  • violates EU law in the areas specified in the Act (e.g. the areas of ​​public procurement, consumer protection, preventing the legalization of proceeds from criminal activity and terrorist financing, or environmental protection).

How to report and to whom?

Whistleblowing notice can be given:

  • to email: whistleblowing@embedit.com

  • by phone: +420 725 193 553

  • during personal appointment (upon agreement with a Nominated Person)

  • in writing to EmbedIT s.r.o., Evropská 17, 160 00 Prague, attn. Roman Loučka

  • through the relevant department of the Ministry of Justice

Nominated Persons include:

  • Martin Šeda, Group Chief Legal & Compliance Officer,

  • Dušan Malota, Chief Administrative Officer, and

  • Roman Loučka, Senior Compliance Manager.

If I am employee of Czech EmbedIT but want to report other issues

Persons who are employees (or similar position) of EmbedIT and want to report issues not falling within the regulatorily-prescribed scope described above may use the email whistleblowing@embedit.com or report to PPF FH Group via (i) personal notification to a staff of PPF FH Group Legal Department, or (ii) web interface at etickalinka.ppf.eu. These issues may be, for example, breach of ethical rules or violation of internal rules and procedures of lesser intensity or impact.

If I am not employee of EmbedIT

Persons who are not employees (or similar position) of EmbedIT, i.e. third parties, can report their concerns to whistleblowing@embedit.com.

Protection

Whistleblowers are afforded the protection of identity and the protection from retaliatory actions. Protection is not provided to whistleblowers who make knowingly false statements and to anonymous whistleblowers until their identity is known.

Code of ethics

Corporate Compliance Program (CCP) of EmbedIT s.r.o. (EmbedIT) is linked to the PPF Group CCP (see https://etickalinka.ppf.eu/. The purpose of the EmbedIT CCP is to prevent any unlawful conduct and if any occurs, to detect it, to rectify it and to take measures so that such or similar conduct is not repeated.

PPF Group, Home Credit Group and EmbedIT values are based on the respect to and compliance with laws and regulations, international treaties, rules of ethics, morals and fair business conduct. This applies to all areas of EmbedIT business and activities and in relation to all third parties, public authorities, and also its employees.

The ​​​​ EmbedIT Code of Ethics as part of the EmbedIT CCP defines fundamental principles, values and benchmarks, including basic rules for:

  • third-party relationships (e.g. prevention of corrupt practices, sanctions screening, disclosure of information to media etc.),

  • internal relationships,

  • safety at work,

  • protection of Home Credit Group and EmbedIT interests (data protection, information security etc.) and

  • environmental protection.

Every EmbedIT employee is obliged to follow the principles and rules set by the EmbedIT Code of Ethics. Basic Principles of Business Conduct and Ethics are available here.