Compliance program

One of the key components of the Czechoslovak Group's anti-corruption program is the Code of Ethics for the holding’s employees who are obliged to adhere to it. Some of its provisions also concern Czechoslovak Group’s partners, e.g. sales representatives and dealers. The Czechoslovak Group Code of Conduct is based on the requirements of the UK-based Transparency International. The Codex includes

As a socially responsible holding operating in the arms industry, Czechoslovak Group's sponsorship activities are logically focused on supporting non-profit activities in the regions where its companies operate. These may be sports, cultural, educational or other activities. Activities in the field of education, which support the development of studies in technical fields that contribute significantly to the national wealth of the Czech Republic, strengthen its export potential and, at the same time, have long faced a shortage of quality students, have a special position among them.

It is a rule of Czechoslovak Group sponsorship that it must not be purposely linked to the realisation of any business opportunity, whether in the public or private sector. Similarly, there must be no sponsorship that would in practice meet the definition of a conflict of interest. Czechoslovak Group generally discloses sponsorship activities in the form of a press release, information on its website, or in CSG's internal magazine.

Support for political parties and movements must be transparent. Such support must not be linked to any public sector business opportunity. Czechoslovak Group strictly complies with all legal obligations regarding any support to political parties.

The Czechoslovak Group provides its partners with standard services in the context of building acceptable professional relationships, including the possibility of covering accommodation costs during the partners' stay and providing gifts and gifts.

However, the provision of unreasonably luxurious accommodation, unethical and costly hospitality and the provision of gifts of manifestly disproportionate value are prohibited. These actions are considered potentially corrupt in relation to Czechoslovak Group partners. Similarly, it is prohibited to accept such unreasonable services or luxury gifts to managers and employees of Czechoslovak Group member companies, especially in their sales departments. In the event that such offers are made by a partner, the employee is obliged to report this fact to his or her supervisor.

At some foreign markets, the state employees are allowed to legally require facilitation payments. It is forbidden for Czechoslovak Group companies to provide these payments. The facilitation payments do not include business provisions for private sector partners, e.g. based on dealer agreements, licence agreements or sales representative contracts.

Although Czech legislation does not allow Czech companies to participate in offset programmes in public procurement by the Czech government and ministries in accordance with European law, they can be required to implement offset programmes when working in foreign environments. A typical requirement, even in democratic countries, can be a partial transfer of production, which can be perceived as a so-called direct offset. Czechoslovak Group, in cooperation with its foreign partners, implements offset programs in strict compliance with national legislation, usually to meet the customer's need to obtain the possibility of partial production and maintenance of the product. Czechoslovak Group rejects and does not participate in offset programs aimed at submitting orders that are not in line with its activities, contain corruption risk and could be used to commit corruption. Czechoslovak Group informs about activities that can be perceived as direct offsets by standard means when disclosing information about the original contract (production transfer is only possible for more significant and publicly auditable projects).

Our company is built on respect for legal compliance and high ethical and moral values. Unlawful or unethical behaviour is unacceptable to us. In an effort to effectively prevent and detect them, we have created an internal whistleblowing system - an ethics hotline - based on anonymity, confidentiality and impartial assessment of each report.

WHAT IS THE PURPOSE OF THE INTERNAL WHISTLEBLOWING SYSTEM?

Employees, contractors, shareholders and members of the Company's elected bodies and other third parties interested in the Company's activities may report suspected violations of law through the Ethics Hotline in accordance with Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons reporting violations of Union law and related Czech legislation ("Legislation") or violations of ethical standards to which the Company has committed itself. Reports may also be made anonymously. Notifications and whistleblowers identified in the Legislation are guaranteed rights under the Legislation, in particular protection of their identity and protection from retaliation. All notifications are dealt with confidentially and impartially and the whistleblower will be informed of the outcome of the investigation if they remain in contact with us.

HOW TO MAKE A NOTIFICATION VIA THE ETHICS HOTLINE?

The web platform is the most recommended way to make a notification as it allows the Notifier to remain completely anonymous if they wish;

TELEPHONE LINE

Notification can also be made by recording a telephone message on +420 234 708 465.

IN-PERSON

Notification can also be made in person to the relevant person, i.e. Mgr. Milan Stupka, tel. (+420) 725 040 176, etika@czechoslovakgroup.cz

EXTERNAL NOTIFICATION SYSTEM

Notifications as defined in the Legislation can also be made through the external notification system established by the Ministry of Justice of the Czech Republic, see https://oznamovatel.justice.cz

HOW WILL PERSONAL DATA BE HANDLED?

Personal data is processed in accordance with the legislation on the protection of personal data. We keep a record of the notifications received, including: (a) the date of receipt of the notification; (b) the name, surname, date of birth and contact address of the notifier, if known; (c) a summary of the content of the notification and the identification of the person against whom the notification was directed, if the identity is known; (d) the date of completion of the assessment of the reasonableness of the notification or the assessment of the notification by the competent person and the result of the assessment. Notifications received shall be retained for a period of 5 years after receipt.

In the case of notifications made through the internal notification system, the register shall be accessible only to the competent person who alone knows the identity of the notifier.