Internal Whistleblowing System

Sparring s.r.o., advokátní kancelář (Sparring) has introduced in accordance with Act No. 253/2008 Coll., Act on Certain Measures against the Legalization of Proceeds of Crime and Terrorist Financing, as amended (AML Act), an internal whistleblowing system pursuant to Act 171/2023 Coll., Act on the Protection of Whistleblowers, as amended (Whistleblowing Act), for the purpose of notifying the infringements that have occurred or are about to occur in connection with Sparring, and has adopted measures to ensure the protection of persons reporting the infringements in accordance with the aforementioned laws.

1. The Competent Person
   Sparring has designated a competent person to receive, assess and deal with reports, who is:
   Mgr. Ondřej Zemek, advokát
2. Who Can Make the Report
   The report may be filed by any person (You) who has directly or indirectly performed or is performing work or other similar activity for Sparring, or who has been or is in contact with Sparring in connection with the performance of work or other similar activity, where work for this purpose means:
   • employment,
   • professional practice, internship or volunteer activities,
   • the exercise of rights and obligations arising from a contract for the provision of supplies, services, or other similar work (either as an entrepreneur or as a company),
   • exercise of rights associated with participation in a legal entity,
   • exercise of the functions of a member of a body of a legal person,
   • applicant for a job/other form of cooperation.
3. How to Make the Report:
   • Reports via the internal whistleblowing system can be made in any of the following ways:
     • in writing in an electronic form: whistle@sparring.io
     • by telephone: +420 606 657 882
     • orally after agreeing a meeting with the competent person at Sparring premises or at another agreed location.

   Reports submitted in writing are usually made on the form available on the website. The report should contain the name, surname and date of birth, or other information from which the identity can be inferred. Information about processing of Your personal data based on Your report can be found here.

   However, it is possible to submit the report even anonymously. In the case of an anonymously reported incident, it is recommended to provide at least an email address so it is possible to communicate with You.

   • In addition to the internal whistleblowing system, you may:
     • file the report with the Department of Justice at the link here, or
     • file the report with the Czech Bar Association (in Czech: Česká advokátní komora) or Financial Analytical Office (in Czech: Finanční Analytický úřad) due to AML Act (in case of violation of the AML Act),
     • make it public, subject to the Section 7(c) of the Whistleblowing Act.

   The report of violation of the AML Act shall never be filed with the Department of Justice and shall never be made public.