Whistleblowing

Internal whistleblowing system for reporting infringements

According to Act No. 171/2023 Coll., on the Protection of Whistleblowers, Canna b2b s.r.o. (hereinafter referred to as the "Obliged Entity") implemented an internal system for reporting unlawful conduct (hereinafter referred to as the "Internal Whistleblowing System"). This system is intended for employees and other individuals who, during their work or similar activities, have obtained information about illegal conduct with the characteristics of a criminal offense or misdemeanor, the fine of which amounts to at least CZK 100,000 according to the law. Such conduct is contrary to the laws of the Czech Republic or European Union law (in particular Directive (EU) 2019/1937).

Notifications may be submitted by:

• an employee of the Obliged Entity,
• a person performing another similar activity for the Obliged Entity pursuant to Section 2 Art. 3 lit. a), b), h) or i) of Act No. 171/2023 Coll.

The obliged entity excludes the receipt of notifications from persons who do not perform work or other similar activities for it pursuant to Section 2 (1) of the Act. 3 lit. a), b), h) or i) of Act No. 171/2023 Coll.

Procedure for submitting a report

The obliged entity allows the submission of notifications in the following ways:

1. In writing – by sending a paper notice to the address of the Obliged Entity's registered office marked "Do not open – confidential (notifier)".
2. By e-mail – by sending a notice to the e-mail address: [email protected].
3. By phone – at +420 774 766 034.
4. Orally – in front of the competent person who records such a report on the record.

The relevant persons are Kateřina Bíliková and Tereza Malá.

In addition to the internal whistleblowing system, the whistleblower has the right to submit a report through the Ministry of Justice of the Czech Republic. This option can be used on the official platform: https://oznamovatel.justice.cz/chci-podat-oznameni

Whistleblower protection and confidentiality

• The report must contain information enabling the whistleblower to be identified. Anonymous reports will not be processed – the obliged entity is not obliged to  receive or handle anonymous reports under Section 2 para. 2 of Act No. 171/2023 Coll. (with exceptions specified in the Act).
• The obliged entity is obliged to maintain confidentiality about the identity of the whistleblower and the content of the report – only authorized persons have access to this information.
• The whistleblower is protected from any retaliation (e.g. termination of employment, deterioration of working conditions) for submitting a report in good faith.

The obliged entity has issued an internal directive that regulates in detail the issue of whistleblower protection, including the exact procedure for filing and handling reports. In case of any ambiguity regarding the procedure, the rules set out in this internal directive shall apply.

Handling reports and abuse

• The obliged entity is obliged to evaluate the notification and decide on further action within 30 days from the date of receipt at the latest.
• In the case of more complex reports, this period may be extended to 60 days – the whistleblower must be informed of the extension of the deadline.
• After investigating the report, the whistleblower will be informed of the outcome and of any measures taken.
• Making a knowingly false report may be considered an abuse of legal protection and may result in disciplinary action or other legal action.
• The obliged entity reserves the right to take steps to protect its rights in the event of knowingly false notifications.