WHISTLEBLOWING - Reporting potential infringements of the regulations
📑 At BNP Paribas Cardif (and the entire BNP Paribas Group) we have always emphasized the importance of integrity, and we take our commitment to comply with all applicable laws and ethical standards very seriously. Our goal is to remain a company where work is carried out in accordance with these principles.
Whistleblowing (the internal system for reporting potential infringements of the regulations) allows you to report information about a criminal offence, breach, violation or attempt to conceal a violation of applicable and binding legal regulations (Acts, regulations, etc.) or a breach of the BNP Paribas Code of Conduct. Reporting of possible unlawful acts in the Czech Republic is governed by the following legislation:
- Act No. 253/2008 Coll., on Selected Measures against Legitimisation of Proceeds of Crime and Financing of Terrorism (AML Act), as amended – applicable for reporting violations of obligations stipulated by the AML Act.
- Act No. 171/2023 Coll., on the Protection of Whistleblowers (Whistleblowing Act), as amended.
If you are a customer of BNP Paribas Cardif and wish to report any dissatisfaction or complaint, please approach: https://cardif.cz/kontakty/podnety-a-stiznosti.
You are on the right page if:
- you are or have been an employee, a person with employment contracts through an agency, or a person with an agreement outside of contract (in Czech: DPČ and DPP);
- you have applied to that person for employment or similar activity;
- you are or have been a self-employed person to that person;
- you are or have been a shareholder of that company;
- you are or have been a member of the board of directors, the supervisory board or a manager or person in the capacity of members of similar bodies of the company;
- you are or have been a person in professional practice or in an the internship or have been a volunteer;
- you are or have been a supplier, contractor, etc., related to rights and obligations arising from the contract, the subject of which is the provision of supplies, services, etc.
- you are or have been in contact with due to work or other similar activity.
In what case should I submit a report?
- If you believe that BNP Paribas Cardif Pojišťovna, a.s. has violated the obligations defined by the AML Act, the report is made in accordance with the AML Act.
- As per the Whistleblowing Act, if you believe that there has been a possible violation which qualifies as a criminal offence; violation which qualifies as an administrative offence punishable by a fine with an upper limit of at least CZK 100,000 (approx. EUR 4,300); violation of the Act; or violation of legal regulation (including EU legal regulation) in selected areas, in particular: public procurement; financial services, money laundering and terrorist financing; consumer protection; data protection, protection of economic competition, etc.
- In case of a violation of BNP Paribas Code of Conduct.
Whistleblowing reports are handled by independent experts (so called Relevant persons) in a confidential manner and in accordance with the regulations in force.
The law prohibits any retaliation against the Whistleblowers or any other protected person. However, any misuse of the reporting system may subject the Whistleblower to legal sanctions.
👁 For more information about the protection of personal data see: https://cardif.cz/ochrana-osobnich-udaju.
How are you protected?
Protection against retaliatory measures belongs to you and others:
- If you submit a report under the Whistleblowing Act anonymously, you and other persons under the Act are protected by the Act only from the moment when your (and/or other persons’ under the Act) identity is revealed to the person who may subject you to retaliation.
- If you submit a report under the AML Act, protection belongs to you even if you submit an anonymous report.
- If you submit a report related to a violation of BNP Paribas Code of Conduct and it is not in the scope of the Whistleblowing Act, you will be protected in line with internal rules but not according to the Whistleblowing Act.
⚠ If you submit a report without having reasonable grounds to believe that it is based on true information (this is, therefore, a deliberately false report), you are committing an offence and protection is not applicable to you.
How can I submit a report?
Please use the contacts (Internal Whistleblowing System) listed below on this page.
If you would like to submit a report externally, meaning using contacts other than those within BNP Paribas Cardif, you can also send a notice of possible violation to:
- Financial Analytical Office (https://fau.gov.cz/kontakty) in the case of a report of a breach of obligations under the AML Act. In such cases, the report cannot be submitted to the Ministry of Justice. It is also prohibited to publish the content of the report if it is subject to the duty of confidentiality under the AML Act.
- Ministry of Justice (https://oznamovatel.justice.cz/chci-podat-oznameni/) if it is a report within the scope of the Whistleblowing Act.
Can I remain anonymous?
- If you submit a report under the AML Act: Yes, your report may be anonymous. Even then you will be protected against possible retaliation.
- If you submit a report under the Whistleblowing Act: The Act defines that a report contains the name, surname and date of birth, or other data from which the whistleblower can be identified. If you submit a report anonymously, we will deal with it in accordance with our internal processes, but we are not obliged to handle it within the time limits and in the manner stipulated by the Whistleblowing Act. In such a case, protection belongs to you only from the moment when your (and/or other persons’ according to the Act) identity is revealed to the person who may expose you and/or other protected persons to retaliation measure.
Will I receive feedback on my report?
Upon receipt of your report, a confirmation of receipt will be sent to you (unless you have explicitly asked not to receive any confirmation; or it is obvious that such information would reveal your identity or the identity of another person). Assuming you provide us with a contact, you will then be informed about the processing of your report and the outcome of the investigation (unless you have explicitly asked not to receive any notification; or it is obvious that such information would reveal your identity or the identity of another person).
Will confidentiality be guaranteed?
Yes, access to reports is limited to the Relevant person only, i.e. the person responsible for receiving and handling reports submitted through the Internal Whistleblowing System. Relevant persons are trained in handling whistleblowing reports confidentially and they take appropriate steps to do so.
Internal Whistleblowing System
You can contact us in the following ways:
- E-mail: firstname.lastname@example.org
- Telephone line (recorded): +420 234 240 560
- Personally upon request
Relevant persons – Lucie Janáčková, Jan Zídek, Tatiana Shavkunová, Kateřina Krist