Whistleblowing notices

Personal data, if obtained from the whistleblower, are processed only for the purpose of evaluating the relevance and resolution of a specific Whistleblowing alert, the legal basis for the processing of personal data is the fulfilment of a legal obligation by Komerční banka under the wording of Act No. 171/2023 Coll., on the Protection of Whistleblowers.

There is no transfer of the collected personal data to third parties, only the exclusive recipients (the so-called Competent Persons, see contacts below) are the recipients. The personal data will be archived for a period of 5 years from the date of receipt of the alert.

Further information regarding the processing and protection of personal data, including the exercise of your rights, can be found on Komerční banka's website.

A person who performs or has performed work or other similar activity for Komerční banka, which means:

1. Dependent work performed in an employment relationship
2. Self-employment
3. Exercise of rights connected with participation in Komerční banka
4. Performance of tasks within the scope of the activities of a legal entity, in its interest, on its behalf or on its account
5. Volunteer activities
6. Professional practice, internship
7. Exercise of rights and obligations arising from a contract the subject of which is the provision of supplies, services, works or other similar performance.

Work or other similar activity includes applying for a job or other similar activity.

Whistleblowing alert can be made:

1. Through the internal whistleblowing system of Komerční banka –  https://report.whistleb.com/en/komercnibanka


2. Through group whistleblowing system of Société Générale (parent company of Komerční banka), if the internal whistleblowing system of Komerční banka is not suitable or cannot be used –  https://report.whistleb.com/en/whsortal/socgengroup


3. To the Competent Persons listed below, with whom you can arrange a personal meeting if necessary: Marcela Nouzová, Compliance Specialist, +420 602 950 533
   Petr Kupsa, Compliance Specialist, +420 720 953 130
   Tomáš Choutka, Head of Regulatory Compliance, +420 602 575 927
   Klára Loudová, Conduct Officer, +420 724 035 492
   
   (hereinafter collectively referred to as "Competent Persons" or "Competent Person")
   Common e-mail address of the Competent Persons to receive Whistleblowing alerts: whistleblowing@kb.cz.
   
   

4. In writing
   To the address of the company at the hands of the Competent Person
   Komerční banka, a.s.
   Nám. Junkových 2772/1
   Praha 5 150 00
   indicate on the envelope "Whistleblowing - DO NOT OPEN"

For the purpose of further communication, please include your name, surname, date of birth or other information proving your identity in the Whistleblowing alert.

You may also make your Whistleblowing alert anonymously.

The whistleblower shall receive written confirmation of receipt of the Whistleblowing alert within 3 working days of its receipt at the latest. At the same time, the whistleblower will be informed whether or not his/her notification falls under the definition of notification pursuant to Act No 171/2023 Coll., on the Protection of Whistleblowers (hereinafter referred to as the "ZoOO") and what rights and obligations he/she is entitled to within this process. The information provided will be treated as strictly confidential.

The Competent Person will proceed with the investigation in such a way that the identity of the whistleblower is not disclosed. At all times during the investigation, the identity of the whistleblower will be known only to the Competent Persons. In the event that it is not possible to proceed with the investigation without disclosing the identity of the whistleblower to other persons, the Competent Person shall inform the whistleblower of this and seek his/her explicit consent to this procedure.

This does not apply in cases where the identity of the whistleblower is requested by public authorities. However, the Competent Person must inform the whistleblower of this fact in advance, together with the reasons for which it is obliged to provide the identity information, and give the whistleblower the opportunity to comment on the provision of the information.

The investigation will then assess the reasonableness of the Whistleblowing alert and other relevant facts. The Competent Person will then inform the whistleblower in writing of the results of this assessment within 30 days of receipt of the Whistleblowing alert. Where the matter is factually or legally complex, the Competent Person may extend this period by 30 days, up to a maximum of twice. In such cases, the Competent Person must always inform the whistleblower of the extension and the specific reasons for it.

No acts of retaliation will be taken against the whistleblower if the Whistleblowing alert is made in good faith and without expectation of financial consideration. If the Whistleblowing alert meets the definition under Section 2(1) of the ZoOO, the whistleblower will be subject to the protections of this Act. In such a case, the Whistleblowing alert may also be made through the external notification system established by the Ministry of Justice. This does not apply in the case of facts that fall under the scope of Act No. 253/2008 Coll., on Certain Measures Against The Legalization of Proceeds of Crime And Terrorist Financing, where the competent authority for dealing with the notification is the Financial Analytical Office.

If your notification or enquiry relates to another area, you will be redirected to another responsible department of Komerční banka.