Whistleblowing

The company Agropoistenie s.r.o., Sartorisova 11, 821 08 Bratislava, Company ID: 47054701 (hereinafter the “Company” or the “independent financial agent” or the “SFA”), in accordance with Section 22(5) of Act No. 54/2019 Coll. on the Protection of Whistleblowers of Anti-Social Activity and on Amendments to Certain Acts, as amended by Act No. 189/2023 Coll., publishes information on the manner in which employees of the Company and other persons (hereinafter “Whistleblowers”) can submit a report of possible unlawful conduct that has occurred or is about to occur in the Company, or at a third party with whom the Whistleblower is or was in contact in connection with work or other similar activity carried out for the Company, through the Company's internal reporting system.

How to submit a report to the Company

A report of anti-social activity (hereinafter the “Report”) can be submitted by a whistleblower through the internal reporting system to the responsible person, who is Ing. Marek Dudáš.

A report can be submitted in the following ways:

By telephone – at telephone number +421 903 380 135, whereby a written record is always made of the telephone conversation.
In writing - by a written consignment delivered to the company's registered office at Agropoistenie s.r.o., Sartorisova 11, 821 08 Bratislava, with the marking “Do not open” on the envelope.
Electronically - to the work e-mail address of the responsible person: dudas@agropoistenie.sk; this way of submitting reports is available continuously 24 hours a day.

A report may be anonymous or non-anonymous. If the person submitting the report does not state their first name, surname and address, the report is considered anonymous.

Procedure after receipt of a report

The responsible person confirms receipt of the report, in paper or electronic form depending on how the report was delivered, within 7 days of its receipt.

The responsible person is obliged to investigate and notify the Whistleblower of the result of the investigation, including any measures adopted to remedy deficiencies, within 90 calendar days from the day the report was received. The period for investigating the report may in justified cases be extended by 30 days, and the responsible person is obliged to notify the Whistleblower (if the report was non-anonymous) of the extension of the period for investigation and the reasons for the extension. Referring the matter for handling under the Criminal Procedure Code or special regulations (e.g. under the Act on Offences) is also considered an investigation of the report.

When investigating a report, the responsible person proceeds from its content, regardless of the person of the Whistleblower and the person concerned. At the same time they are entitled to request files, documents or materials related to the investigated report, and to request cooperation from the Whistleblower or a supplement to the report. Every employee of the Company is obliged to refrain from any conduct that would hinder the submission or investigation of a report.

The responsible person is obliged to maintain confidentiality about the identity of the person who submitted the report throughout the investigation of the report and after its conclusion. The duty of confidentiality applies to the same extent to other employees who become aware of the identity of the person submitting the report, regardless of how or for what reason they learned the identity of that person. A report must not be investigated by the person concerned, nor by their subordinate employee, nor by an employee who took part in the activity that is the subject of the report.

Who can be a Whistleblower - is entitled to submit a report.

A Whistleblower means, under Section 2 of the Act, a natural person who in good faith makes a report to the authority competent to receive the report or to the employer; a whistleblower is also considered to be a natural person who in good faith:

makes a report and whose employment relationship or other similar relationship has ended, if they learned the information about anti-social activity during that employment relationship or other similar relationship,
makes a report and whose employment relationship or other similar relationship has not yet arisen, if they learned the information about anti-social activity during a selection procedure or within pre-contractual relations,
made a report anonymously and whose identity was revealed,
disclosed information about anti-social activity that they learned during a selection procedure or within pre-contractual relations and whose employment relationship or other similar relationship had not yet arisen, or during the employment relationship or other similar relationship, or after the end of the employment relationship or other similar relationship, on the grounds that

they made a report through the internal system for investigating reports and were not informed of the result of the investigation under Section 10(8), or no appropriate measures were adopted under Section 10(8), and subsequently made such a report to the authority competent to receive the report and were not informed within a reasonable period of the status of the investigation or of the result of the investigation,
they made a report to the authority competent to receive the report and were not informed within a reasonable period of the status of the investigation or of the result of the investigation,
there is a justified concern that the anti-social activity may constitute an immediate or obvious threat to the public interest, or
there is a justified concern that, if a report were made to the authority competent to receive the report, they would face retaliation or, in view of the specific circumstances of the case, there is a risk that the authorities receiving the report would not ensure an impartial and independent investigation of the facts stated in the report.

Protection of the whistleblower

Submitting a Report must not become a motive or a ground for drawing consequences that would cause the person submitting the report any harm. No one may threaten with retaliatory measures or penalise by retaliatory measures the whistleblower or a person close to the whistleblower, or persons under Section 1(4)(a) to (e) of the Act on the Protection of Whistleblowers. The whistleblower and a person under paragraph 4(a) to (e) cannot waive the right to protection against penalisation by retaliatory measures.

Advice and consultations

In connection with reporting anti-social activity, advice is provided by the Whistleblower Protection Office. The Office provides the opportunity to consult free of charge with the Office's lawyers on matters concerning the reporting of anti-social activity and on the options for protecting Whistleblowers. The form is available at: Form https://formular.oznamovatelia.sk/form/mail

Contact:

Office for the Protection of Whistleblowers of Anti-Social Activity, Námestie slobody 29, 811 06 Bratislava, https://www.oznamovatelia.sk/

Processing of personal data

The Company is entitled to process the personal data stated in a report to the necessary extent:

first name, surname, residential address of the person submitting the report, telephone number, e-mail address.

The purpose of processing personal data under this internal regulation is:

investigating reports and keeping records of them,
performing the employer's tasks,
protecting the rights or legally protected interests of the employer or third parties.

The categories of data subjects in processing personal data under this regulation are:

the person who submitted the report and
persons who were named in the report.

When processing personal data, the Company is obliged to ensure the protection of personal data and its security. To ensure the security of the processing of personal data, the Company has adopted technical and security measures under the Personal Data Protection Act.