member of groupMetalimex


Internal Regulation No.099


by which


company                    OKK Koksovny, a.s.

registered address      Koksární 1112, Přívoz, PSČ  702 24 Ostrava

ID no.:                        47675829

(the “employer”)


hereby issues this



Internal Regulation on the Protection of Whistleblowers




General Provisions

I.1.      This Internal Regulation stipulates the conditions and procedure for the receipt of reports by employees, the method of handling reports and the method for handling obtained information in a way that is in accordance with generally binding statutory regulations valid in the Czech Republic, and in particular Directive (EU) 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Union law (“legislation”).


I.2.      This Internal Regulation introduces an internal reporting system for the employer, i.e. the liable entity, as defined in the relevant legislation.


I.3.      The receipt of reports, the manner of handling reports and the manner of handling information will be carried out exclusively in accordance with legislation, with an emphasis on the confidentiality and protection of whistleblowers and jointly protected persons.


I.4.      The employer hereby states that the competent person for the performance of activities as defined in the relevant provisions of the Whistleblower Protection Act is:


Jana Zimová

+420 224 492 243,

Štěpánská 621/34, 110 00 Praha 1


I.5.     For the purposes of submitting written reports, the employer shall also set up a physical box, which is located on the employer's premises and marked with the company logo and the word “WHISTLEBLOWING”. In OKK Koksovny, a.s. the mailbox is located in the premises of the workers' gatehouse near the coffee machines.


Basic Definitions


For the purposes of this Internal Regulation, the following terms have the following meanings:


report” – notification from a natural person containing information about a possible breach which has the characteristics of a criminal offense or transgression, or which infringes European Union laws or regulations governing the following areas:

about which the whistleblower has become aware in connection with their work or similar activities; for the purposes of this Act, work or other similar activity is also defined as an application for a job or other similar activity;


authorized person” – person designated by the employer in article I (4) of this Internal Regulation;


whistleblower” – natural person who has submitted a notification of possible unlawful actions;


jointly protected person” – person who, together with the whistleblower, cannot be subject to retaliatory measures, and who is defined as a:



retaliatory measures” – actions relating to the work or similar activity performed by the whistleblower and which were provoked by the report and which may cause harm to the whistleblower or jointly protected person. These include in particular:


Ministry” – the Czech Ministry of Justice, ID no.: 000 25 429, registered address Vyšehradská 427/16, 120 00 Praha 2.


Reporting and post-reporting procedure

III.1.   Submission and receipt of reports


III.1.1. The whistleblower is entitled to submit a report, orally and/or in writing, to the Ministry and/or the relevant entity through an internal reporting system set up by the employer. If the whistleblower so requests, the entity concerned shall be required to receive the report in person within a reasonable time frame, but within a period not exceeding 30 days.


III.1.2. Whistleblowers who submit a report in writing may do so:


III.1.3. The whistleblower may disclose the information which constitutes the content of the report if:



III.1.4. The entity concerned shall notify the whistleblower in writing of the receipt of a report under this Internal Regulation within seven days of its receipt, unless:



III.1.5. The whistleblower is entitled to submit the report anonymously.


III.2.   Assessment of the merits of the report submitted


III.2.1. The entity concerned shall assess the merits of the report and inform the whistleblower in writing of the results of this assessment within thirty days of receipt of the report. In factually or legally complex cases this period may be extended by up to thirty days, but not more than twice. The entity concerned is obliged to notify the whistleblower in writing of the extension of the time limit and the reasons for its extension, prior to its expiry, unless:



III.2.2. If the entity concerned finds that the report:



III.3.   Taking appropriate measures


III.3.1. If the report is found to have merit, the entity concerned shall propose to the employer appropriate measures to prevent or remedy the illegal situation, which the employer shall take, or take other appropriate measures.


III.3.2.The employer shall immediately notify the entity concerned of the measures taken. The entity concerned shall then immediately notify the whistleblower of these measures in writing, unless:



III.4.   Rules for the provision of data


III.4.1. The entity concerned shall not be entitled to provide information that may frustrate or jeopardize the purpose of the report.


III.4.2. Information on the identity of the whistleblower and the jointly protected person may be provided only with their written consent, unless the entity concerned is obliged to provide this information to the competent public authorities under other legislation. This also applies to information concerning the identity of the person mentioned in the report.


Recording, registration and storage of reports


IV.1.   Recording of oral reports


IV.1.1. In the case of an oral report, an audio recording (with the whistleblower's consent) or a transcript of such will be made. The entity concerned shall give the whistleblower an opportunity to comment on the transcript. The whistleblower's comments shall be attached to the transcript.


IV.1.2. The entity concerned may not make a recording or transcript without the consent of the whistleblower. In such a case, they must write a record that faithfully captures the substance of the oral report. The entity concerned shall give the whistleblower an opportunity to comment on the record. The whistleblower's comments shall be attached to the record. The same procedure shall be followed if it is not technically possible to make an audio recording of the oral report.


IV.2.   Registration and storage of reports


IV.2.1. The entity concerned shall keep records of received reports in electronic form. These must contain the following information:



IV.2.2.Reports and the information specified above are kept on record for a period of five years from the date of their receipt. Only the entity concerned shall have access to these records.


Offenses of whistleblowers


Whistleblowers shall receive a fine of up to 50,000 CZK for knowingly submitting a false report.


Final Provisions


VI.1    This Internal Regulation shall be valid for an indefinite period of time and take effect on 14 February 2022.


VI.2.   This Internal Regulation may be amended by the employer at any time by issuing a new full text at least one calendar week before the amendment takes effect.


VI.3.   All employees of the employer shall be acquainted with this regulation and shall receive proper training in its principles and application.


VI.4.   This Internal Regulation is also published in the company's usual internal system.



In Ostrava  28.02.2022

Ing. Pavel Woznica, v.r.


Chairman of the Board of Management


OKK Koksovny, a.s.


OKK Koksovny, a.s. se sídlem Ostrava-Přívoz, Koksární ulice 1112, PSČ 702 24,zapsaná v obchodním rejstříku vedeném Krajským soudem v Ostravě, oddíl B, vložka 740, IČO: 47675829, DIČ: CZ47675829. Společnost OKK Koksovny, a.s. je členem koncernu kde řídící osobou je společnost MTX Group a.s., IČO: 27441261