Introduction and purpose of policy

AURES Holdings a.s. (“the Company”) strives to create a working environment that supports open and fair communication within the Company and in relation to its customers, and which protects the Company, its employees and clients against fraud, unethical or discriminatory conduct and against other undesirable phenomena, occurring either within the Company or outside. The Company pledges that persons filing honest reports of such fraudulent or unethical conduct will not be penalized.

In its efforts to fulfil this commitment the Company has introduced this whistleblower policy for reporting undesirable situations and phenomena, the aim of which is primarily:

  • to set out and publish procedures for the receipt of reports relating to internal or external fraud, unethical conduct, discrimination and similar undesirable phenomena, whether such reports are filed by a Company employee or an external entity
  • to set out and publish procedures guaranteeing honest whistleblowers confidentiality and anonymity, if requested, and which also guarantee that honest whistleblowers will be in no way penalized for their activity


Basic principles

Any sanctions or recriminations in relation to an honest whistleblower are strictly prohibited. Employees that violate this ban or the ban on anonymity in relation to an honest whistleblower will be penalized, and will possibly face immediate dismissal. Any employee who assumes they have been subject to sanctions or recriminations for their whistleblowing in accordance with this policy may report the matter to their direct superior, to any member of the Company’s supervisory board, to the internal audit director or to the internal safety group manager

However, it must be emphasised that employees who knowingly and deliberately file untrue or distorted reports will not be protected by this policy and may also be penalized, including possible immediate dismissal.


Reporting methods

The Company has defined the following four ways for filing a confidential report concerning undesirable situations and phenomena:

  • special email address
  • internet form available below
  • report delivered by post to AURES Holdings a.s., Dopraváků 874/15, 184 00 Praha 8 – Čimice
  • via the Notification Line on the Intranet in the Internal Audit&Rules section

Access to any of the above reports is strictly restricted to the internal audit director and the internal safety group manager. The person filing the report may request anonymity and the Company undertakes to comply with any such request. Reports may be filed in any language in which the Company actively operates, i.e. in Czech, Slovak, Hungarian and Polish. The Company has arranged for a confidential translation service for the reports it receives.


Handling of reports

Reports received under the protection of this policy will be documented and archived for five years from the date of receipt in the internal audit department. Access to documentation will be strictly restricted to members of the Company’s supervisory board, internal audit staff and internal safety staff.

All honest reports will be checked immediately and in a responsible and professional manner by the internal audit department or internal safety department to the extent necessary to ensure that the report is assessed in a fair and professional manner. These and only these two departments will also carry out any subsequent investigations and will define remedial measures in relation to the report.


Claims and standard customer complaints

This whistleblower policy in no way duplicates or overlaps the Company’s standard policy in relation to customer claims, aiming to provide the Company’s customers with fair and lawful access to claims proceedings on the basis of standard client contracts.

The Company undertakes to investigate any conduct reported that shows signs of fraud, is in violation of the law, internal regulations, code of ethics or good morals. Such conduct should first be reported to the whistleblower’s direct superior. If this is not appropriate or possible for any reason, the report may be filed using any of the ways of reporting undesirable situations and phenomena as specified below.





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