In accordance with Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (hereinafter referred to as the "Whistleblower Protection Act") and Act No. 253/2008 Coll., on certain measures against the legalization of the proceeds of crime and the financing of terrorism (hereinafter referred to as the "AML Act"), Drivalia Lease Czech Republic s.r.o. has set up an internal reporting system for the submission of information about possible illegal activities. At Drivalia Lease Czech Republic s.r.o., we encourage our employees and any other persons to report conduct that may be contrary to the binding rules or values that Drivalia Lease Czech Republic s.r.o. upholds.
Drivalia Lease Czech Republic s.r.o. informs the whistleblower that in addition to the internal reporting system specified below, he/she may also direct his/her report directly to the Ministry of Justice. The whistleblower is free to choose which reporting system to use.
In the case of reports relating to facts falling within the scope of the AML Act, the competent authority for receiving the reports under the external reporting system is the Financial Analysis Authority.
A fine of up to CZK 50,000 may be imposed on the whistleblower for deliberately filing a false report.
Authorised employees of the Risk & Compliance Department (hereinafter referred to as the "Whistleblowing Officer") are responsible for receiving and managing the reports. The Whistleblowing Officer receives and manages the report submitted by an employee of Drivalia Lease Czech Republic s.r.o. or a person performing volunteer activities or other similar activities for Drivalia Lease Czech Republic s.r.o. (contractors, self-employed persons, employees of contractors, etc.), and subsequently notifies the whistleblower of the handling of his/her notification within the time limits prescribed by law.
The following categories of suspicious behaviours can be reported under this policy:
These principles do not apply to complaints about employment or interpersonal relations in the workplace. Please contact Human Resources to resolve employment issues or any other matters. For matters relating to occupational health and safety, all suspicions should be reported in accordance with the relevant policy, except for serious breaches where you are concerned to report the suspicion through the normal procedures. These principles also do not apply to the handling of any complaints or grievances about services provided to the customers of Drivalia Lease Czech Republic s.r.o.
Whistleblowers must have reasonable grounds to suspect that the reported information indicates one or more relevant suspicions that fall within the scope of this policy. Suspicions may relate to past, present or likely future events. It is not necessary for the whistleblower to obtain definitive proof. It is sufficient if the suspicions are based on good faith arising from the circumstances prevailing at the time of the report. If you are unsure whether to report your suspicions, it may be helpful to discuss them with your line manager or another manager you can trust who is not connected to the matter. It is important that you do not discuss your suspicions with any person involved in the matter you are reporting, or share your suspicions with anyone other than the person from whom you have sought confidential advice.
In particular, we will ask you for the following information when you submit your report:
A report can be submitted:
Only employees can report a whistleblowing issue by telephone to the Whistleblowing Officer at +420 222 829 319, every working Thursday between 9:30 and 12:00, telephone conversations are not recorded.
A date for a personal meeting with the Whistleblowing Officer will be arranged within 14 days of receipt of the request for a meeting (by e-mail, telephone).
For the purpose of further communication, please include your name, surname, date of birth or other identification in the report. Each report must also include information about the possible violation that has occurred or is about to occur.
The report can also be made anonymously. If a whistleblower makes an anonymous report, he or she is not subject to the legal protection of the Whistleblower Protection Act (prohibition on retaliation, particularly against the whistleblower or persons close to the whistleblower), nor are applicable the time limits set out in the Whistleblower Protection Act.
The reporter shall receive a written acknowledgement of receipt of the report no later than 7 days from the date of receipt. At the same time, the whistleblower will be informed whether or not his/her report falls within the definition of the Whistleblower Protection Act and what rights and obligations he/she has in this process. The information provided will be treated as strictly confidential.
The Whistleblowing Officer will conduct the investigation in a manner that does not reveal the identity of the whistleblower. Throughout the investigation, the identity of the whistleblower will be known only to the whistleblower. In the event that it is not possible to proceed with the investigation without disclosing the identity of the whistleblower to others, the Whistleblowing Officer will inform the whistleblower of this and seek the whistleblower's explicit consent to this procedure.
The investigation will then assess the validity of the report and other relevant facts. The Whistleblowing Officer will then notify the whistleblower in writing of the results of this assessment within 30 days of receipt of the report. Where the matter is factually or legally complex, the Whistleblowing Officer may extend this time limit by 30 days, up to a maximum of twice. In these cases, the Whistleblowing Officer must always inform the whistleblower of the extension and the specific reasons for it.
The conclusions of the assessment will then be forwarded in anonymised form to the designated persons of Drivalia Lease Czech Republic s.r.o., together with any proposals for the elimination of the identified deficiencies or mitigation of the identified risks. If, as a result of the assessment of the report, measures are taken to remedy the identified deficiencies or mitigate the identified risks, the Whistleblowing Officer will inform the whistleblower thereof. The action taken or the information provided must not undermine or compromise any interest protected by law, including the purpose of criminal, misdemeanour or other proceedings in respect of conduct that constitutes an offence.
As a member of the CA Auto Bank Group, Drivalia Lease Czech Republic s.r.o. processes all personal data relating to whistleblowing exclusively within the EU. In addition, facts, information or documents covered by state defence secrets, medical secrets or attorney-client privilege are excluded from the whistleblowing system.
Although misuse of the notification exposes its author to possible sanctions or legal proceedings, it should be specified that a notification made in good faith, even if it subsequently turns out that the facts are inaccurate or lead to any continuation, does not expose its author to any disciplinary sanction. Nor can natural persons be prosecuted for disclosing facts subject to banking secrecy. No person shall be sanctioned, dismissed or subjected to any direct or indirect discriminatory measure, in particular as regards remuneration or promotion, for having exercised his/her right to act as a whistleblower.
Disclosures shall be treated with the strictest confidentiality. Information identifying the whistleblower may not be disclosed except to legal authorities and only with his or her consent. Elements that could identify the person to whom the whistleblowing relates cannot be disclosed except to legal authorities and only after the legitimacy of the whistleblowing has been verified.
The whistleblowing reports collected are intended for the Drivalia Lease Czech Republic s.r.o. Whistleblowing Officer and/or the Crédit Agricole SA Group Point of Contact in particular if it is impossible to reach the local Whistleblowing Officer, who processes the report in complete confidentiality. The whistleblower is kept informed of the follow-up given to his or her report and its closing.
The data relating to a report that is deemed, as soon as it is collected by the Whistleblowing Officer, as not falling within the scope of the whistleblowing right will be destroyed or archived without delay, after undergoing anonymisation. When the report is not followed by disciplinary or judicial proceedings, the data relating to this report will be destroyed or archived after undergoing anonymisation by the Group within twelve months of the closure of the verification operations. When disciplinary proceedings or legal proceedings are instituted against the person concerned by the report or against the author of an abusive report, the data relating to the report are kept by the Group until the end of the relevant proceedings. In any case, the data subject to archiving measures will be kept, as part of a separate information system with restricted access, for a period not exceeding the length of litigation proceedings.
You may at any time under the conditions provided by law access the personal data about you, oppose their processing for legitimate reasons or request rectification, deletion or limitation of their processing. These actions can be achieved through the DSAR contact form. If this is not possible, you can contact the DPO of Crédit Agricole SA at: donnees.personnelles@credit-agricole-sa.fr. In the European territory, you can, in the event of a dispute, file a complaint with the data protection authority which is territorially responsible for your Entity.