Compliance Program

COMPLIANCE PROGRAM

BASIC INFORMATION

Česká zbrojovka a.s. (hereinafter the “Company”) is aware of its responsibility for the positive development of society and, to this end, takes measures that are in strict compliance with the law and based on moral and ethical principles. To ensure compliance with moral and ethical principles, together with procedures in accordance with the law, the Company has established a compliance management system and committed to adhering to its principles and developing its tools.
The compliance management system is a corporate management system consisting of activities and procedures aimed at preventing, detecting, and responding to conduct that would violate internal policies and applicable law and potentially result in criminal liability of the legal entity.

The compliance management system at the Company consists of the following instruments:

Code of Ethics, to which all employees of the Company are committed. 

Compliance Officer, who is an employee appointed by the Company’s Board of Directors and is responsible for the operation and oversight of the compliance management system.

Whistleblowing, which represents a set of measures designed to detect misconduct by providing information to persons or entities that can investigate reported matters and take appropriate action, if necessary (e.g., the Compliance Hotline).

Mandatory Training for all employees of the Company, focused on legal regulations relevant to their respective functions and on the prevention of criminal liability of legal entities.

Set of measures (internal standards, work procedures, principles) designed to eliminate the risks of criminal liability for the Company.

REPORTING ILLEGAL OR UNETHICAL CONDUCT

One of the most valuable assets of the Company is its integrity. Illegal or unethical conduct is unacceptable to the Company. In order to prevent such conduct, the Company encourages the reporting of any such conduct. To detect potential illegal conduct, the Company has established an internal reporting system in accordance with Act No. 171/2023 Coll., on the Protection of Whistleblowers (“Law”), based on confidentiality and impartiality in the assessment of each report.

Who can file a report through the internal reporting system?
Company employees, members of management and statutory bodies may file reports through the internal reporting system. In accordance with the Law, the internal reporting system may not be used to identify persons who do not perform work or other similar activities for the Company.

What is the purpose of the internal reporting system?
Company employees, members of management and statutory bodies may use the internal reporting system to report suspected violations of legal regulations specified in the Law.
Reports and whistleblowers, as defined in the Law, are guaranteed rights arising from the Law, in particular the protection of their identity and protection against retaliatory measures. All reports shall be handled confidentially and impartially, and the reporter shall be notified of the results of the investigation provided that the reporter maintains contact with the Company. In accordance with the Law, the Company is not obligated to address anonymous reports.

How do I file a report through the internal reporting system?
Online Report 
Utilize the internal reporting system available at https://coltczg.whistlelink.com

In-Person Report    
The relevant persons are:
Mgr. Pavel Dolák, LL.M., Deputy General Counsel, +420 724 550 579, email dolak@coltczgroup.com or compliance@coltczgroup.com
Mgr. Veronika Pechalová, Compliance Specialist, +420 775 403 966, email pechalova@czub.cz or compliance@coltczgroup.com
You may contact the relevant persons to arrange a personal meeting for face-to-face reporting.

External Reporting System
Reports defined in the Law may also be made through the external reporting system established by the Ministry of Justice of the Czech Republic.

How will personal data be handled?
Personal data are processed in accordance with data protection laws. The Company maintains records of submitted reports to the following extent: (a) date of receipt of the report; (b) first name, last name, date of birth, and contact address of the reporter, if known; (c) summary of the report’s content and identification of the person against whom the report was directed, if known; (d) the date of completion of the assessment of merits of the report or the assessment of the report by the relevant person, and the result of the assessment. Submitted reports are retained for a period of 5 years from their receipt.
In the case of reports submitted through the internal reporting system, only the relevant persons have access to the records.