Technické sítě Brno, akciová společnost (hereinafter referred to as “TSB”), which is a member of the SMB Group and for which the Statutory City of Brno is its managing person, is a joint stock company with its registered office at Barvířská 5, 602 00 Brno. In an effort to combat any illegal (including criminal) and unethical behaviour, it has created, implemented and operates the Compliance Programme of Technické sítě Brno, a.s. (hereinafter referred to as “CP_TSB”), which is a set of interrelated and enforced measures. The basic principles of the CP_TSB are described in the Code of Ethics, which outlines the values, principles, measures and practices considered key by TSB. The Code also declares the corporate culture in this area.

TSB’s management abides by the belief that any behaviour that may damage the company’s reputation or the reputation of the Statutory City of Brno (as the managing person of SMB Group) and that may adversely affect its market position is considered extremely undesirable.

TSB acknowledges the social interest in crime prevention and detection and in averting the consequences of a crime committed. TSB also acknowledges the social responsibility that arises from TSB’s status as a public contracting authority that regularly issues tenders in accordance with Act 134/2016 Coll. on Public Procurement. TSB expends all efforts that may be fairly required to prevent an unlawful act being committed and to avert or eliminate as far as possible any consequences of an unlawful act committed within its jurisdiction.

TSB also acknowledges both its responsibility towards its employees and its responsibility for the conduct of employees or other persons (in particular persons defined in Section 8 of Act No. 418/2011 Coll., on the Criminal Liability of Legal Entities and Proceedings Against Them). TSB is also aware of its responsibility in the area of environmental protection.

Code of Ethics TSB

Rules for using the whistle-blowing hotline

The whistle-blowing hotline is the primary means for reporting illegal or unethical conduct. The whistle-blowing hotline is available to any person who may believe that such conduct is being committed by TSB employees or others.

The whistle-blowing hotline is set up to ensure the anonymity or confidentiality of a whistle-blower. The identity of a whistle-blower is kept confidential at all times. Information about the identity of a whistle-blower is known only to a predefined group of persons. The confidentiality of the identity is maintained throughout the investigation of the notification, even after its completion. All persons involved in the investigation are obliged to maintain the confidentiality of the cases under investigation, thus guaranteeing the protection of any whistle-blowers. The confidentiality of the identity of a whistle-blower may be broken only in cases provided for by generally binding legislation and where the whistle-blower expressly objects to the confidentiality of his or her identity.

The reporting of illegal or unethical behaviour will not be penalised, even indirectly, unless the reporting is done with the intention of harming a person through false information.

A whistle-blower may make a report using the form located at the bottom of this page. If a whistle-blower wishes to do so, information about the progress and outcome of the investigation of his/her report will be communicated to him/her via the Whistle-blowing Hotline (again, in the strictest confidence).

For TSB’s employees who do not have access to the Internet, a Whistle-blowing Hotline Box has been set up and is located at the company’s headquarters. The Box is positioned to ensure the anonymity of the whistle-blower.

In addition to the Whistle-blowing Hotline and the Box, illegal and unethical conduct may also be reported directly to the Compliance Officer on +420 545 424 014, to the e-mail address compliance(at)tsb.cz or in writing to:

Compliance Officer
Technické sítě Brno, akciová společnost
Barvířská 5
602 00 Brno

The whistle-blower may also at any time make a report under the Criminal Procedure Code to the public prosecutor or the police authority (Section 158(2) of the Criminal Procedure Code). To report a suspected fraud or other serious irregularity that may have a negative impact on EU funds, whether it concerns revenue, expenditure or assets owned by the EU institutions or suspected serious misconduct by staff of the EU institutions, you can use the web form on the European Anti-Fraud Office (OLAF) website:

http://ec.europa.eu/anti_fraud/investigations/report-fraud/index_cs.htm
(http://ec.europa.eu/anti-fraud/olaf-and-you/report-fraud_en)

or at the postal address:

European Commission
European Anti-Fraud Office (OLAF)
1049 Brussels
Belgium

All information and data communicated through the Whistle-blowing Hotline is secured against misuse, stored and archived in accordance with the legal requirements for data protection and personal data protection. Data security is ensured by a set of technical, organisational and physical measures. Any personal data obtained from a whistle-blower are collected, stored and processed in the interests of TSB and the CP_TSB policy. They will be retained for the duration of the investigation of the reported conduct and thereafter for a period of 5 years from the date of completion of the investigation.
Any investigation of reported unlawful or unethical conduct must be completed within 30 days, unless it is a complex investigation requiring cooperation with law enforcement authorities or requiring the interview of multiple witnesses or the obtaining of multiple pieces of evidence. Where a whistle-blower expresses an interest and his/her identity or contact details are therefore known, he/she will be informed of the progress and outcome of the investigation.

Content of the report

Any reported misconduct must include, as a minimum (mandatory information):

» date of the report,
» type of the reported misconduct,
» period during which the reported conduct occurred,
» entities or persons concerned,
» description of the reported misconduct.

In addition, if the whistle-blower considers it appropriate, it is a good idea for the report to include (optional information):
» full name of the whistle-blower,
» contact details of the whistle-blower,
» legal entity or other clarifying information about the whistle-blower,
» other information or documents proving the misconduct.

The more detailed the information in the report, the faster and more smoothly the actual investigation of the reported conduct will proceed. The whistle-blower also has the right to submit and supplement any additional documents or information confirming the relevance of his/her report and proving the misconduct. The submission of information that is demonstrably incorrect, misleading or false may lead to potential sanctions against the whistle-blower if it is proven that he/she submitted the information intentionally and knew that it was incorrect, misleading or false.