The Whistleblower Protection Act sets a deadline of December 15, 2023 for the implementation of an internal whistleblowing system. This deadline applies to employers employing more than 50 employees, as well as other entities such as capital market operators, insurance companies or persons authorized to broker insurance, and others.
The notification system must designate a "competent person" who will independently assess the validity of the notifications, and after their assessment, propose to the obliged entity measures to remedy and prevent the unlawful situation, while protecting the identity of the notifier.
Obliged entities must publish the means of submitting notifications, both through their internal system and through the portal of the Ministry of Justice, and other information according to the law in a way that allows remote access, i.e. through the website. For at least five years, a record must be kept of notifications to which only the competent person has access.
Failure to comply with the obligation to implement an internal whistleblowing system is punishable by a fine of up to CZK 1,000,000. If you are not sure whether you are obliged to introduce an internal whistleblowing system, or if you have not yet introduced the system as an obliged person, or if you are not sure that its regulation is fully in accordance with the law, please contact us. We will be happy to discuss with you all the steps involved in implementing the system, whether it is the obligation to implement it or its specific set-up.