Whistleblowing - reporting illegal actions

Internal reporting system Jet Investment, a.s. (hereinafter referred to as the “Company”)

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‍Report

An employee who discovers apossible illegal act that has occurred or is about to occur at the Company forwhich he/she has performed or is performing work or other similar activity,even indirectly, or at the Company with which he/she has been or is in contactin connection with the performance of work or other similar activity, and who:

  1. has the characteristics of a crime,
  2. has the characteristics of an offence for which the law stipulates a fine, the upper limit of which is at least CZK 100,000,
  3. violates Act no. 171/2023 Coll., on the Protection of Whistleblowers, as amended (hereinafter referred to as the "Act on the Protection of Whistleblowers"),
  4. violates another legal regulation or a regulation of the European Union in the field
    • of financial services, statutory audit and other assurance services, financial products and financial markets,
    • corporate income tax,
    • prevention of money laundering and terrorist financing,
    • consumer protection,
    • compliance with product requirements, including their safety,
    • safety of transport, carriage and operation on land roads,
    • environmental protection,
    • food and feed safety and protection of animals and their health,
    • radiation protection and nuclear safety,
    • competition, public auctions and public procurement,
    • protection of public order and security, life and health,
    • protection of personal data, privacy, and the security of electronic communications networks and information systems,
    • protection of the financial interests of the European Union, or
    • functioning of the internal market, including the protection of competition and state aid under European Union law,

may, in accordance with thefurther modified procedure, internally report such a breach or imminent breachthrough a special communication channel (hereinafter referred to as the “BreachReport”). The Breach Report is a tool for communicating significant concernsregarding possible violations of the above-mentioned legal regulations,including any possible threat to the proper and reliable functioning andeffectiveness of the Company's management and control system, and subsequentassessment of the validity of these concerns and the adoption of correctivemeasures, if such measures are necessary.

Workor other similar activity at the Company pursuant to the previous paragraphmeans the following activities performed for the Company:

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  1. dependent work performed in a basic employmentrelationship,
  2. service,
  3. self-employment,
  4. exercise of rights associated with participation in alegal entity,
  5. performance of the duties of a member of a legalentity’s governing body,
  6. performance of tasks within the activities of thelegal entity, in its interest, on its behalf, or for its account,
  7. trust fund management,
  8. volunteering,
  9. professional experience, internship, or
  10. the exercise of rights and obligations arising from acontract, the subject of which is the provision of supplies, services,construction work or other similar performance,
  11. as well as applying for a job or other similaractivity.

The Company does not exclude receiving reports from a person who does not perform work or other similar activities for the Company - an obligated entity pursuant to paragraph 1.2 letter a), b), h) or i) of the Whistleblower Protection Act.

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Reportinvestigation procedure

Reporting a violation can bedone anonymously or non-anonymously. Reports should be made in good faith, sothe notifier should be reasonably convinced of the truthfulness of theinformation provided in the report, even in the case of an anonymous report.

Report of a violation mustalways contain a description of the facts on the basis of which the notifierconcludes that there is a violation or imminent violation of the aboveregulations. The report may be accompanied by documents or other data carriers thatthe notifier relies on in his judgment. The report may include thewhistleblower’s contact details, to which the relevant person and theirrepresentative, both designated by the Company under Paragraph 10 of theWhistleblower Protection Act as responsible for receiving and assessing thevalidity of a violation report (hereinafter jointly referred to as the‘relevant person,’ or individually as the ‘relevant person’ and the‘representative’)—may reach out to the whistleblower, if necessary, tosupplement or clarify the facts stated in the report.

The person of the notifierand the persons pursuant to Section 4, para. 2 letter a) to h) of theWhistleblower Protection Act are protected within the meaning of Section 4 ofthe Whistleblower Protection Act, i.e. they must not be subject to retaliation.Within the framework of the set internal reporting system, it is particularlyensured that:

  1. only the relevant person can become familiar with thesubmitted report;
  2. the relevant person shall maintain confidentialityregarding facts that he or she has learned while performing his or heractivities, even after the performance of these activities has ceased, unlessthe law states otherwise;
  3. the relevant person does not provide information thatcould defeat or compromise the purpose of the report;
  4. the relevant person may provide information about theidentity of the whistleblower and the person pursuant to Section 4 paragraph 2letter a) to h) of the Whistleblower Protection Act only with their writtenconsent, unless the relevant person is obliged to provide this information tothe relevant public authorities under other legal regulations.
  5. The report of a violation may be written or oral andis submitted to the relevant person, or to their representative, who is listedbelow. In the case of a written report, it is sent in paper form via a postalservice provider to the following address:
    Jet Investment, a.s.
    Whistleblowing
    Hlinky 49/126, 603 00 Brno, Pisárky
    or it may be sent via email to the email addresses of the relevant person andtheir representative listed below. In the case of an oral report, it may bedone by telephone at the telephone numbers of the relevant person and theirrepresentative listed below or, at the request of the notifier, in person atthese persons at the address listed above in this paragraph. 1.6; in the caseof a personal report, the relevant person is obliged to accept the report inperson within a reasonable period of time, but no later than 14 days from thedate on which the notifier requested it. A record will be made of the oralreport, or, with the consent of the notifier, a recording. A competent personshall allow the whistleblower to comment on the recording or transcript of theaudio recording, if any, and the whistleblower's comments shall be attached tothe recording or transcript.
  6. The report of a violation is handled by the relevantperson, or their representative, who are designated by the Company and who willverify the facts stated in the report.
  7. The relevant person is obliged to notify the notifierin writing of the receipt of the report within 7 days of its receipt, unless i)the notifier has explicitly requested the relevant person not to notify him ofthe receipt of the report, or ii) it is clear that notification of the receiptof the report would reveal the identity of the notifier to another person.

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Evaluationof the investigation

The report will be evaluatedas justified or unjustified:

  1. Based on this evaluation, a justified report will befurther investigated while maintaining the protection of the identity of thenotifier. The competent person is obliged to notify the notifier in writing ofthe results of the assessment within 30 days of the date of receipt of thereport. In cases that are factually or legally complex, this period may beextended by up to 30 days, but not more than twice. The relevant person isobliged to notify the notifier in writing of the extension of the deadline andthe reasons for its extension before its expiry. Exceptions to the obligationto provide written report pursuant to paragraph 1.8 shall apply in the sameway. If the report is assessed as justified, the competent person will proposemeasures to the obligated entity to prevent or remedy the illegal situation. Ifthe report is filed with the relevant person of an obliged entity for which thenotifier does not perform work or other similar activity, the relevant personshall propose corrective measures to the person for whom the notifier performswork or other similar activity, unless the nature of the matter precludes this.If the obliged entity does not take the measure proposed by the relevantperson, they shall take other appropriate measures to prevent or remedy theunlawful situation; this does not apply if the measure is proposed to a personother than the obliged entity that designated the relevant person. The obligedentity shall immediately notify the relevant person of the measure taken, whoshall notify the notifier in writing without undue delay. Exceptions to theobligation to provide written report pursuant to paragraph 1.8 shall apply inthe same way.
  2. If the report is not assessed as justified, therelevant person shall, without undue delay, notify the reporting party inwriting that, based on the facts stated in the report and the circumstancesknown to them, they have not found any suspicion of an unlawful conduct, orhave found that the report is based on false information, and shall inform thereporting party of their right to file a report with a public authority.

After the investigation andmutual agreement, the relevant person shall forward the anonymized case of thereported violation or threatened violation to the Board of Directors of theCompany with a proposal to adopt corrective measures or prevent the unlawfulsituation in connection with the submitted report, unless this procedure couldresult in the disclosure of the identity of the whistleblower or a personpursuant to Section 4, paragraph 2 letter a) to h) of the WhistleblowerProtection Act. The Company's Board of Directors is responsible for thedecision to adopt a corrective measure and assign tasks for its implementation.

All employees of the Companyare obliged to provide the relevant person with the cooperation requested forthe purpose of verifying the facts stated in the violation report and theproposed corrective action.

The relevant person keepsrecords of data on reports received in electronic form. The relevant person isobliged to keep the report submitted through the internal reporting system andthe documents related to the report for a period of 5 years from the date ofreceipt of the report.

In accordance with paragraph16 and the following Whistleblower Protection Act, it is also possible to filea report with the Ministry of Justice.

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Designation of the relevant person and his/her representative

whistleblowing@jetinvestment.cz

Gabriela Tlačbabová, tlacbabova@jetinvestment.cz, 725 740 502

Milan Gašo, gaso@jetinvestment.cz, 731 790 446

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