Compliance

This Code of Ethics of the SYNOT Group (hereinafter referred to as the "Code of Ethics") is issued as an internal regulation of the individual companies within the SYNOT Group and forms part of the corporate culture of these companies and, consequently, the entire SYNOT Group.
The purpose of this Code of Ethics is to prevent illegal activities, eliminate behavior that threatens the good reputation, economic interests, and profits of the SYNOT Group, and to ensure legal and ethical business practices of the companies in the SYNOT Group in all countries where the SYNOT Group operates through these companies.

The Code of Ethics is a binding set of values to which the daily work activities and behavior of employees are subordinated, and it is intended to help employees recognize the line between ethical and unethical behavior.

The companies SYNOT W, a.s., SYNOT TIP, a.s., SYNOT ICT Services, a.s., and SYNOT GASTRO SLOVAKIA s.r.o. process your personal data exclusively in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Czech legislation. We recognize the importance of protecting personal data and approach this matter with the utmost seriousness.
This document applies universally to the aforementioned companies and pertains to the protection of personal data of individuals (data subjects). For SYNOT W, a.s., it covers all purposes of personal data processing listed below. For SYNOT TIP, a.s., SYNOT ICT Services, a.s., and SYNOT GASTRO SLOVAKIA s.r.o., it specifically relates to the processing of notifications received through the internal reporting system. The processing of personal data is governed by internal regulations.

INFORMATION FOR WHISTLEBLOWERS ACCORDING TO THE WHISTLEBLOWER PROTECTION ACT

Who is Authorized to Make a Notification
The person authorized to submit a notification and to whom the protective measures under the Act apply is the Whistleblower, who has performed or is performing work or similar activities for the respective company, including applying for a job or engaging in similar activities. This includes:

1. Employment performed under a basic employment relationship,
2. Serving as a member of the governing body of a legal entity,
3. Volunteer activities,
4. Internship or professional practice,
   (collectively referred to as the “Whistleblower”).

In accordance with § 9 (2) (b) (3) of the Act, the SYNOT Group excludes the acceptance of notifications from individuals who:

1. Engage in self-employment,
2. Exercise rights associated with participation in a legal entity,
3. Carry out tasks on behalf of, in the interest of, or for the account of a legal entity,
4. Manage a trust fund,
5. Exercise rights and obligations arising from a contract for the supply of goods, services, construction works, or similar performance.

With respect to notifications related to violations of Act No. 253/2008 Coll. on Certain Measures Against the Legalization of Proceeds from Crime and Terrorist Financing (hereinafter referred to as "AML"), notifications will be accepted from all individuals listed in points (a) to (i).

Areas Covered by Notifications
Notifications regarding possible illegal conduct within the SYNOT Group, according to Act No. 171/2023 Coll. on Whistleblower Protection (hereinafter referred to as the "Act"), can be made if you have information about potential illegal conduct that has occurred or is about to occur in one of the companies of the SYNOT Group, which:

1. Has the characteristics of a criminal offense,
2. Has the characteristics of an administrative offense for which the law provides for a fine with an upper limit of at least CZK 100,000.00,
3. Violates the law,
4. Violates the SYNOT Group Code of Ethics,
5. Violates AML law,
6. Violates other legal provisions or European Union regulations in the areas of

1. 1. Financial services, mandatory audits, and other verification services, financial products and financial markets,
   2. Corporate income tax,
   3. Prevention of money laundering and terrorist financing,
   4. Consumer protection,
   5. Compliance with product requirements, including safety,
   6. Transport safety, transit, and operation on public roads,
   7. Environmental protection,
   8. Food safety and animal health protection,
   9. Radiation protection and nuclear safety,
   10. Competition, public auctions, and public procurement,
   11. Protection of public order and safety, life, and health,
   12. Protection of personal data, privacy, and the security of electronic communications networks and information systems,
   13. Protection of the financial interests of the European Union, or
   14. Functioning of the internal market, including competition protection and state aid under European Union law.

Content of the Notification
The notification must include the name, surname, and date of birth of the Whistleblower or other data from which the identity of the Whistleblower can be inferred, except for notifications concerning AML violations, which can be submitted anonymously. The notification must be specific, clear, and should indicate against whom it is directed and what conduct it relates to, so that it can be properly investigated. The notification must also contain relevant information about the possible illegal conduct, including any related documents, records, images, and audiovisual recordings. Please note that the Whistleblower commits an offense by knowingly submitting a false notification, which may incur a fine of up to CZK 50,000.

Except for notifications regarding violations of AML law, which can be submitted anonymously, the SYNOT Group warns that complete anonymity of the Whistleblower may practically complicate, prolong, or completely hinder the investigation of the notification and any subsequent measures to prevent illegal conduct. Therefore, the Relevant Person will only register such anonymous notifications (excluding AML violations) and will not address them further under the Act until the identity of the Whistleblower is determined.

Person Authorized to Receive and Process Notifications (hereinafter referred to as the “Relevant Person”):
The following individuals are responsible for receiving and processing notifications regarding possible illegal conduct within the SYNOT Group at the respective companies:

1.       SYNOT W, a.s.: Mgr. Simona Horáčková, LL.M., tel. +420 739 604 111, email: [email protected]

2.       SYNOT TIP, a.s.: Mgr. Simona Horáčková, LL.M., tel. +420 739 604 111, email: [email protected]

3.       SYNOT ICT Services, a.s.: Mgr. Aleš Doležálek, LL.M., tel. +420 739 604 132, email: [email protected]

4.       SYNOT GASTRO SLOVAKIA s.r.o.: Mgr. Aleš Doležálek, LL.M., tel. +420 739 604 132, email: [email protected]

5.       Synot Live, s.r.o.: Mgr. Jan Pluhař, tel. +420 724 143 575, email: [email protected]

Ways to Submit Notifications within the SYNOT Group Internal Notification System
Notifications regarding possible illegal conduct within the SYNOT Group can be submitted in the following ways:

1. Electronically via the email of the Relevant Person at the respective company concerned.
2. In writing by sending a letter to the address:

Attn: Mr./Ms. (Relevant Person at the respective company concerned)

Jaktáře 1475

Mařatice

686 01 Uherské Hradiště

Marked "CONFIDENTIAL - DO NOT OPEN"

1. Through the web form at www.synotgroup.com.
2. By phone at the number of the Relevant Person at the respective company concerned.
3. In person in the form of a meeting with the Relevant Person arranged via phone or email. The Relevant Person is obligated to accept the notification within a reasonable period, but no later than 14 days from the date requested by the whistleblower.

Phone calls or personal meetings will be recorded; if you do not consent to an audio recording, the Relevant Person will ensure that a record is made. In this case, the Whistleblower will have the opportunity to comment on the record, and this comment will be attached to the record.

Protection of the Whistleblower
The Relevant Person will maintain strict confidentiality regarding your identity, data about other individuals, and the information contained in the notification. Furthermore, any retaliatory measures against the whistleblower or other individuals are strictly prohibited.

Institution for Alternative Notification Submission
In addition, notifications can be alternatively submitted to the Ministry of Justice of the Czech Republic, even if you have not used the internal notification system of the SYNOT Group, at the address: https://oznamovatel.justice.cz/ (external notification system).

In the case of notifications regarding violations of AML law, the competent authority is the Financial Analytical Office, at the address: https://fau.gov.cz/oznameni-o-podezrelem-obchodu.