AAA Auto Group Whistleblower Policy


Please read carefully the following chapters:

Introduction and purpose
Basic principles
Procedures to collect the disclosures
Procedures to elaborate the disclosures
Periodic reporting
Customer claims and standard grievances

 

Introduction and purpose


AAA Auto N.V. (the "Company") intends to introduce and maintain such internal working environment, which supports fair and open communication and protects the Company, our employees and customers from unlawful practices, internal frauds or discriminations, be it of internal or external nature. We intend to state clearly that proper disclosures of any such illegal or unethical conduct will not be subject of retaliation of the reporter.

In an effort to pursue this commitment and to comply to the market standards and Dutch Corporate Code of Conduct, this whistle blower policy is introduced, by which we intend to:


    • establish and publish procedures for reception of disclosures regarding internal or external frauds, unethical behaviors or discriminations, be it of internal or external nature and be it reported by the Company employee or external stakeholder
    • establish and publish procedures to guarantee that received disclosures will be treated in a confidential (and anonymous if required) manner and to make clear that any retaliatory behavior will be disciplined, up to the termination of the employment

 

Basic principles

The Company commits itself to act on any serious wrongdoing or malpractice within the company. An infringement of Code of Conduct, a law or internal regulations, as well as any other serious misconduct or malpractice shall primarily be reported to the local management. If, however, for any reason this is not possible or desirable, the reporter is invited to take use of the below outlined means of disclosure reception.

Retaliation against any employee who submits a disclosure under this whistle blower policy is strictly prohibited. Employees determined to have engaged in retaliatory behavior or who fail to maintain an employee’s anonymity if requested may be subject to discipline, which could include termination of employment. Any employee who feels that he or she has been subjected to any behavior that violates this policy should immediately report such behavior to his or her supervisor, Non-executive Chair of the Board of Directors of AAA Auto N.V., Director of Internal Audit or the Group Manager of Internal security.

However, we state clearly, that employees who intentionally file ungrounded, misleading or false allegations, will not be protected by this policy and may be subject to discipline, including termination of employment

 

Procedures to collect the disclosures

The Company has introduced four basic means of reception of disclosures under this policy

    • special mailbox notice@aaaauto.cz
    • intranet form available on the Company’s website (/en/notice)
    • direct surface mail: AAA Auto International a.s., Director of the Internal audit department, Chlumčanského 5, 180 21, Prague 8 – Liben, Czech republic

 Access to any of the four disclosure reception means is strictly limited to the Director of Internal Audit and Group Manager of Internal Security. Reporters may require anonymity and in such cases the Company commits itself to respect that desire. The reporters may submit their disclosures in any of the Company home languages, i.e. in Czech, Slovak, Hungarian, Polish or Romanian languages. The Company has arranged for confidential translation service of the disclosures.

 

Procedures to elaborate the disclosures

Disclosures collected under this policy will be documented and archived for five years by Internal audit department. Only Members of the Board of AAA Auto, Internal audit and Internal Security will be allowed to access the files, if requested.

All disclosures will be promptly, seriously, discreetly and professionally addressed by Internal audit and / or Internal Security departments to the extent that is considered as appropriate and necessary as a response to that disclosure. These and only these two units shall also engage themselves in any kind of investigations and subsequent actions.

 

Periodic reporting

Internal audit will quarterly inform Members of the Board of the Company about numbers and basic facts relating to the investigations performed under this policy. General sponsor of this aggregated reporting will be the Non-Executive Chairman of the Board of Directors of the Company, which under Czech law corresponds to the position of the Chairman of the Supervisory Board.

 

Customer claims and standard grievances

This whistle blower policy is not intended to intervene with and does not replace the standard reclamation process, which is set up to ensure fair and law-compliant treatment of customer claims originated from the ordinary business activities.

 



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