Introduction

This directive is valid and binding for all employees and cooperating individuals of Benefit Management s.r.o., ID 27069770 (hereinafter referred to as the “Company”).

The purpose of this directive is to set the rules for internal control to prevent criminal activities, detect criminal offenses, and establish related regulations, in compliance with Act No. 418/2011 Coll. on Criminal Liability of Legal Entities and Proceedings against Them and Act No. 171/2023 Coll. on the Protection of Whistleblowers.

This directive is available in electronic form upon request to any employee or cooperating individual of the Company; the original directive is stored with the Company’s management.

The rules outlined in this directive can also be utilized by other individuals filing notifications based on Act No. 171/2023 Coll.

Basic Compliance Rules

The Company has established and maintains control mechanisms and procedures for monitoring activities at all organizational and managerial levels.

The Company has developed a system of internal regulations in various compliance areas, particularly in the fields of:

• Protection against money laundering,
• Personal data protection,
• Anti-corruption measures,
• Ethical conduct.

All employees are required to strictly adhere to all legal regulations, directives, internal regulations, and other relevant contractual documents.

Preventive Compliance Activities

The Company has developed a system of rules that employees must follow. These rules are written clearly to ensure every employee understands them. Employees are familiarized with these rules during onboarding and at regular intervals throughout their employment, as well as on an ad-hoc basis when necessary.

The Company particularly trains employees who might encounter situations with any potential for criminal activity. Employees can also seek advice from the Company outside of these training sessions if they have any questions.

The Company carefully selects its employees, requiring them to present a clean criminal record before employment. When necessary, the Company may also obtain a job reference or verify the candidate’s previous activities through other legal means.

The Company has established an internal structure that aligns with the qualifications of individual employees. Each employee has defined duties and authorities to prevent or significantly reduce the risk of unlawful acts.

The Company ensures it collaborates only with verified suppliers and clients in business matters to avoid being involved in illegal activities due to choosing an unreliable business partner. For this purpose, the Company thoroughly checks suppliers and clients using all reasonably expected means and includes compliance clauses in contractual documents.

The Company also conducts regular compliance checks on employee behavior in specific areas. Records of these checks are maintained.

Compliance Officer

The Company has appointed a Compliance Officer responsible for the entire compliance area. The appointed Compliance Officer is Mgr. Eliška Kutnohorská, MBA, tel. +420 225 377 777, email: compliance@benefit-plus.eu.

Any employee or cooperating individual can contact the Compliance Officer if they suspect any criminal activity within the Company. The Compliance Officer can be contacted anonymously via the provided email or by sending a letter to the Company’s registered address. Notifications can also be sent via email in audio form.

In addition to the above, the Compliance Officer regularly monitors relevant rules and legal regulations, sets and adjusts necessary processes within the Company, coordinates all compliance activities, ensures adherence to established rules, and provides advisory services in this area.

Whistleblowing

The Company respects whistleblowing rules, i.e., the protection of individuals reporting criminal activities. Whistleblowers are protected against any illegal reprisals for reporting or suspecting criminal activities.

The Compliance Officer is the designated person to handle matters related to reporting criminal activities.

If the report is not made anonymously, the whistleblower will be notified of the report’s receipt within seven days. The report must be resolved within 30 days of its receipt, and the whistleblower will be informed of the resolution unless the report was made anonymously. This resolution period can be extended in justified cases.

Actions in Case of Identifying Unlawful Conduct

The Company rejects any criminal activity or unethical behavior and will immediately take appropriate action upon discovering such conduct.

If an employee or cooperating individual suspects criminal activity or any activity violating internal regulations or ethical principles (hereinafter referred to as “incident”), they have the right to report it to the Compliance Officer.

All reported incidents will be duly recorded and investigated. If the whistleblower requests it, the Company is obliged to inform them within a reasonable time of how their report was handled, except if the report was made anonymously.

Any such report is subject to confidentiality by the Compliance Officer and the Company’s management, except in cases specified by legal regulations. Whistleblowers are also subject to the rules outlined in the Personal Data Protection Directive.

If the Company, based on its investigation, finds that the incident could involve criminal activity, it is obliged to immediately refer the matter to the Czech Police. If the Company, after its thorough investigation, determines that no legal regulations were violated, it will document the investigation’s methods and results.