Internal Whistleblowing System

A whistleblowing system is a secure internal system through which employees of the IEM CAS can report violations that have occurred or may be underway.

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In accordance with Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 (open in a new window) on the protection of persons who report breaches of Union law (“Directive”), the Institute of Experimental Medicine CAS (“IEM CAS”) has appointed competent persons for accepting and investigating reports of unlawful actions (“competent persons”).

The main objective of protecting whistleblowers is to create conditions allowing unlawful actions to be identified, which are committed in the workplace or during the performance of work or other similar tasks.

Report of Unlawful Action

A report may be filed solely by a natural person who ascertains (in connection with work or another similar activity, including employment, service, services provided on an independent contractor basis, practicum, internship) a potentially unlawful action that appears to meet the definition of a criminal offense, an infraction, or a violation of laws or European Union regulations pertaining to the areas defined under the Directive.

Areas

  • financial institutions, financial services, financial products, and financial markets;
  • corporate income tax;
  • money laundering and terrorist financing;
  • consumer protection and safety and conformity to requirements for products in accordance with the law;
  • transport safety pertaining to persons and cargo and road safety;
  • environmental protection, food and feed safety, animal health and welfare;
  • protection from radiation and nuclear safety;
  • public procurement, public auctions, and economic competition;
  • protection of internal order and security, life, and health;
  • protection of privacy and personal data, and security of information systems and electronic communication networks; protection of the European Union’s financial interests;
  • functioning of the internal market, including the European Union’s rules relating to economic competition and government subsidies.

The competent person is responsible for receiving and assessing reports and, where applicable, recommending to the IEM CAS, an obliged entity, measures to remedy an ascertained unlawful state of affairs. The competent person must notify the whistleblower of report receipt within seven days and of the way in which it was handled no later than within three months. All documents processed in connection with a report must be kept on file during a period of five years.

The IEM CAS and competent persons guarantee to whistleblowers that facts will remain confidential, which they learn during the conduct of their duties and thereafter. In addition, a guarantee is provided to whistleblowers regarding the complete protection of their personal data.

In accordance with the Directive, whistleblowers reporting unlawful actions meeting the definitions laid down under the Directive can use the following communication channels.

Reporting Forms

  • By e-mail to the secured e-mail address jehne@jehnevodak.cz.
  • By regular email to:
    Jehne & Vodák Law Firm, Washingtonova 1567/25, 110 00 Prague.
    The envelope containing a report must be clearly marked as follows: INTERNAL WHISTLEBLOWING SYSTEM – CONFIDENTIAL, DO NOT OPEN, DELIVER TO COMPETENT PERSON ONLY
  • By telephone at +420 222 232 061, +420 222 232 062.
  • In person – based on prior written or telephone arrangement with the competent person.

A filed report is made available solely to competent persons who examine whether the report is substantiated.

Competent Persons

  • Robert Jehne, an attorney with the Jehne & Vodák Law Firm with registered office at Washingtonova 1567/25, 110 00 Prague 1
  • Vladimíra Bláhová, an attorney with the Jehne & Vodák Law Firm with registered office at Washingtonova 1567/25, 110 00 Prague 1

The IEM CAS is unable to guarantee the protection of the whistleblower’s identity and information stated in a report in accordance with the Directive in case that the whistleblower files a report through communication channels other that listed in this document, for example though the mailroom or via a data box.

Other Forms of Reporting

In addition, a report can be filed through:

  • An external reporting system, specifically by filing a report with the Ministry of Justice of the Czech Republic (the method for filing a report is described on the Ministry website (open in a new window)).
  • Publication, i.e. making information stated in the report available in the public domain (for example on social media, through the media, or on a website); publication is subject to the conditions laid down in the Directive, specifically:
    • no appropriate measure is adopted in response to the report within the prescribed time limits;
    • the absence of action on the whistleblower’s part is liable to endanger an important public interest, for example, due to the danger of delay;
    • a report cannot be filed with the Ministry of Justice without being exposed to an increased risk (for example the destruction of evidence, action frustrating proper investigation, or retaliation against the whistleblower).
    • The publication should be used under exceptional circumstances only, where the intended purpose cannot be achieved by filing a report using the standard channels (the IEM’s Internal Whistleblowing System or a report filed with the Ministry of Justice).
  • A report filed directly with the applicable government authority (Police, administrative authority).