Whistleblowing – Reporting Channels for Potential Wrongdoings

CoinifyNex s.r.o. (referred to as "the Company") complies with § 9 of Act No. 171/2023 Coll, known as the "Whistleblower Protection Act," and related legal provisions. We provide information on how Company employees and authorized individuals (referred to as "Whistleblowers") can report actual or potential violations occurring within the Company or involving third parties with whom the Whistleblower has interacted in connection with their work or related activities for the Company. Reports can be submitted through both the Company's internal reporting system and the external reporting system operated by the Ministry of Justice and the Financial Analytical Office.

Types of Violations Reportable Under the Whistleblower Protection Act

According to the Whistleblower Protection Act, individuals can report to the Company or the relevant state authority any violations that fall under the following categories:

a) Behaviors with characteristics of criminal offenses;

b) Actions meeting the criteria of a misdemeanor punishable by a fine with a minimum upper limit of CZK 100,000;

c) Breaches of the Whistleblower Protection Act itself;

d) Violations of other legal regulations or European Union directives in various domains, including but not limited to:

  • Financial services, statutory audit, and assurance services, as well as financial products and markets
  • Corporate income tax regulations
  • Measures to prevent money laundering and terrorist financing
  • Safeguards for consumer protection
  • Compliance with product standards, including product safety
  • Measures ensuring traffic, transport, and road safety
  • Protection of the environment
  • Safety measures related to food, feed, and the welfare of animals
  • Regulations for radiation protection and nuclear safety
  • Ensuring fair economic competition, overseeing public auctions and procurement processes
  • Measures to maintain internal order, security, and safeguarding life and health
  • Safeguards for personal data protection, privacy, and security of electronic communications networks and information systems
  • Protection of the financial interests of the European Union
  • Ensuring the smooth functioning of the internal market, including protection of competition and regulation of State aid under European Union law.

Who Can Submit a Notification (the Whistleblower)

Under the Whistleblower Protection Act, the following individuals are entitled to submit a notification:

a) The managing director or a member of the supervisory board

b) Shareholders of the Company

c) Employees of the Company working under an employment contract, a task completion agreement, or a work agreement

d) Tied agents of the Company (if they are natural persons)

e) Employees or members of the statutory body of the Company's tied agents

f) Third parties to whom certain Company activities have been delegated (if they are natural persons), or their employees or representatives, or third-party contractors providing supplies, services, construction work, or similar under contract to the Company

g) Individuals undertaking voluntary work, work experience, or internships with the Company

h) Applicants or prospective applicants for roles mentioned above (a) to (g).

How to Submit the Notification 

The Whistleblower has the option to submit their notification through the Company's internal reporting system, either in writing or verbally to the designated Competent Person.

Notifications can be submitted in the following ways:

  • Via email to: support@coinifynex.com
  • In paper format or in person at the Company's registered office, located at [address]
  • Upon the Whistleblower's request, the Competent Person will arrange to receive the notification in person within a reasonable timeframe, not exceeding 14 days from the date of the Whistleblower's request.

External Notification Systems

Ministry of Justice:

You can report a potential violation under the Whistleblower Protection Act through the external notification system managed by the Ministry of Justice. This system can be accessed on the website: https://oznamovatel.justice.cz/chci-podat-oznameni/

Financial Analytical Office (referred to as the "FAO"):

If an offense involves a breach of Act No. 253/2008 Coll., which addresses measures against the legitimization of proceeds from crime and terrorism financing (known as the "AML Act"), the report should be made via the external notification system administered by the FAO. Contact information for submitting notifications can be found on the FAO's website: https://fau.gov.cz/kontakty

Please note: Reports of AML Act violations cannot be submitted through the Ministry of Justice's notification system and are exclusively received by the FAO.

Additional Information:

For more detailed procedures, protections, and the rights of individuals reporting concerns, please refer to the Company's internal regulation titled "WHISTLEBLOWING - SYSTEMS FOR NOTIFICATION OF POSSIBLE ILLEGAL ACTIVITIES." If you require further assistance, you can also reach out to the Ministry of Justice through their website.

Date: Prague, 14/03/2024

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