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    Reporting Misconduct in FILTER GROUP

    Supporting a safe, fair, and transparent workplace

    Why it matters

    For FILTER Group, it is important to protect our business, values, and principles, ensure fair and correct conduct, safeguard the well-being of our employees, and prevent unfair or unequal treatment. Individuals who witness something that violates the laws of the country and/or FILTER’s principles are asked to report it.

    The group of individuals from whom we expect reports is not limited, but the report must be related to FILTER GROUP or its employees and must contain information about a breach. A whistleblower (reporter of misconduct) may be any employee of a FILTER company (including interns) in any of our home markets, a member of the management board or supervisory board, as well as a FILTER client, cooperation partner, subcontractor, or any other person connected to FILTER Group.

    A breach is considered an action or omission that is clearly unlawful or contrary to the company’s principles, internal rules, or established practices.

    illustration

    Please use the reporting channel to report:

    • Conflict of interest

      For example, purchasing from a company in which the employee has a personal interest.

    • Corruption, bribery, financial misconduct

      For example, accounting fraud, manipulation with invoices or expense reports or any other improper activity that harms the company’s financial interests.

    • Falsifying data, manipulating information, misuse of confidential or sensitive business information.

      For example, disclosing internal pricing strategies to external parties

    • Intentional damage to the company property or negligence

      For example, intentionally breaking tools or equipment, carelessly handling machinery, resulting in damage, ignoring maintenance procedures that lead to breakdowns.

    • Damage to an employee’s property

    • Theft, misappropriation, embezzlement

      For example, taking company tools, equipment, or materials for personal use; using company car or fuel card for a private purpose if not agreed so.

    • Unequal treatment, bullying, discrimination, or harassment of an employee

    • Violation of good practice, inappropriate or rude behavior

      For example, using rude, aggressive, or disrespectful communication; behaving unprofessionally with customers or colleagues; misusing authority or humiliating team members.

    • Any crime or failure to fulfill legal obligations

    • Violation of conditions of licenses or permits issued to the company

    • Violation of the law or the employment rights

    • Occupational health and safety concerns

      Endangering or harming someone’s occupational health and safety. For example, not using mandatory personal protective equipment; ignoring safety procedures.

    • Environmental protection

      For example, failure to report a situation where it has become known that our activities harmed or may have harmed the environment through pollution or otherwise.

    • Non-compliance with company regulations

      Failure to follow company rules, procedures, or internal regulations. For example, ignoring IT security guidelines, such as password rules.

    • Intentional concealment of information related to any of the above

    • Any other serious concerns

      Any action that could expose the company to legal, financial, or reputational risk.

    • Conflict of interest
    • Corruption, bribery, financial misconduct
    • Falsifying data, manipulating information, misuse of confidential or sensitive business information.
    • Intentional damage to the company property or negligence
    • Damage to an employee’s property
    • Theft, misappropriation, embezzlement
    • Unequal treatment, bullying, discrimination, or harassment of an employee
    • Violation of good practice, inappropriate or rude behavior
    • Any crime or failure to fulfill legal obligations
    • Violation of conditions of licenses or permits issued to the company
    • Violation of the law or the employment rights
    • Occupational health and safety concerns
    • Environmental protection
    • Non-compliance with company regulations
    • Intentional concealment of information related to any of the above
    • Any other serious concerns
    A person reporting misconduct must have a reasonable basis to believe that a breach has begun or been completed and that the information provided is accurate.

    The channel is not intended for submitting false or malicious information. In normal circumstances, the company expects concerns to be resolved within the team or with the help of the immediate supervisor. If this is not possible for any reason, the company encourages reporting work-related misconduct. Misconduct can be reported through the whistleblowing line or by contacting FILTER Head of Group HR directly. In the whistleblowing line, it is possible to submit a report confidentially or anonymously.

    • illustration When submitting a confidential report, the whistleblower discloses their identity

      The person handling the report (HR Director) is obligated to ensure confidentiality and may deviate from this only with the whistleblower’s consent.

    • illustration When submitting an anonymous report

      The whistleblowing line ensures anonymity, and the person processing the report (HR Director) cannot identify the whistleblower. If the content of the report makes the identity identifiable, it will still be treated as anonymous.

    Excluded matters

    The whistleblowing line is not intended for resolving private-life-related issues, as FILTER GROUP does not intervene in employees’ personal matters. The whistleblowing line is also clearly not intended for:

    • Malicious or revenge-motivated reports
    • Reports about everyday interpersonal misunderstandings or personal issues
    • Employee complaints about work organization, dissatisfaction with pay, working hours, etc. These issues should be addressed with the direct manager who made the decision.

     

    Whistleblowing Line

    FILTER Group’s whistleblowing line is operated on an external partner’s platform, FaceUp, where reports can be submitted confidentially or anonymously. The platform is managed by the Czech company FaceUp Technology s.r.o., which ensures the security and encrypted data exchange of the whistleblowing line. FILTER GROUP provides feedback and communicates with the whistleblower through the whistleblowing line.

    • How to Use the Whistleblowing Line?

      To report misconduct, start by clicking the “Submit a Report” button and selecting the type of incident from the dropdown menu on the next page. This will open the reporting form.

      We understand that submitting a report can be emotionally difficult, but accurate information is essential for resolving the incident. When describing the breach, focus on facts: record as precisely as possible what happened, when, where, who did what, and who is aware of the incident.

    • The following fields are mandatory when reporting misconduct:

      • Time or time period when the incident occurred
      • Location of the incident
      • Persons involved (name and, if possible, job title)
      • Detailed description of the incident (facts, damages caused)
      • What action you expect to be taken and what you see as the best possible outcome

      If documents or other evidence supporting the facts exist, they should be attached to the report. Additional materials help in understanding the issue and resolving it effectively.

      Before clicking “Send,” the whistleblower can choose to remain anonymous or provide the report confidentially.

    • Submitting a Report Anonymously

      If the whistleblower does not wish to disclose their identity, they must check the box “I want to submit this report anonymously.” After clicking “Send,” the system will display a code that allows the whistleblower to track their report and communicate anonymously with the person handling it (HR Director). The code must be copied or saved securely. Without the code, the whistleblower cannot access the report or communicate about the case.

      The whistleblower can also choose to receive email notifications about updates related to the report. The email address will not be shown to the person processing the report. If the content of the report allows the whistleblower’s identity to be inferred, it will still be treated as anonymous.

      The whistleblower should bear in mind that anonymity may significantly complicate the resolution of the case.

    • Submitting a Report Confidentially

      If the whistleblower wants to submit a report confidentially and unchecks the box “I want to submit this report anonymously,” a field will appear to enter their name and contact details. In this case, the person handling the report ensures confidentiality, meaning information about the whistleblower may be shared only with their consent. If additional employees need to be involved to resolve the case, the whistleblower’s consent will be requested before disclosing their identity. However, if the report leads to the initiation of criminal proceedings, confidentiality generally cannot be guaranteed.

    • What Happens After the Report is Submitted?

      The report received is analyzed by the person handling it, who also decides on further actions and whether other individuals need to be involved. The whistleblower is informed of the next steps within seven calendar days, unless they have expressly prohibited such communication or if it could compromise their anonymity or confidentiality. If other employees must be involved, the whistleblower’s consent is sought before disclosing their identity.

      The whistleblower will receive follow-up information on the measures taken within three months, unless they have prohibited it or it would compromise their anonymity or confidentiality.

      For transparency, the report handler will inform individuals significantly affected by the report—primarily those whom the report concerns—after the process is completed. Such notification may be omitted only in exceptional circumstances, and the decision must be documented.

    • Important Considerations When Submitting a Report

      • Knowingly, submitting false information is punishable by law.
      • Confidentiality of the whistleblower cannot be absolutely guaranteed. If criminal proceedings are initiated, confidentiality generally cannot be maintained.
      • If the report is submitted anonymously or the whistleblower does not consent to reveal their identity when necessary, it may be significantly more difficult or impossible to resolve the case.
      • FILTER Group is not obligated to respond to clearly malicious, unfounded, or anonymous reports if the circumstances of the case cannot be determined.
      • Reports and related documents (unless subject to longer retention periods under other legislation or required to be stored in FILTER Group’s document management system) will be retained in the whistleblowing line for three years from the time feedback on follow-up measures is provided to the whistleblower.

    If you have witnessed misconduct or behavior that violates our principles, you have a safe place to report it. FILTER Group’s whistleblowing line provides a protected channel to raise concerns and receive follow-up.

    Submit a Report