AML

1. Introduction

The Internal Reporting System (hereinafter referred to as "IRS") of RK MoWio s.r.o., ID: 11880856, registered office at Evropská 657/120, 160 00 Prague 6 – Dejvice, registered in the Commercial Register under C 355825, kept by the Municipal Court in Prague (hereinafter referred to as the "Company"), is primarily established to prevent potential unlawful actions under Act No. 253/2008 Coll., on certain measures against the legalization of proceeds from crime and the financing of terrorism, as amended (hereinafter referred to as the "AML Act"), and Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (hereinafter referred to as the "whistleblower protection act").

IRS is intended for employees of the Company and other natural persons with a relationship to the Company, providing them with the opportunity to report suspicions of a criminal offense, misdemeanor, or other harmful actions without fear of prosecution, with the assurance that their report will be properly investigated, and appropriate measures will be taken to rectify any wrongdoing. It is also a priority of the Company to ensure the protection of whistleblowers in accordance with the law mentioned above.

2. Reporting

In accordance with the provisions of Section 2 of the whistleblower protection act, reports containing information about possible unlawful conduct that has occurred or is expected to occur within the Company can be made through this IRS by:

• whistleblowers, even indirectly, performing or having performed work or any similar activity

• with which the whistleblower has or had contact in connection with the performance of work or any similar activity.

Unlawful conduct in this context means actions that:

• Qualify as a criminal offense,
• Exhibit signs of a misdemeanor for which the law prescribes a fine of at least CZK 100,000,
• Violate the law or
• Violate other legal regulations or European Union regulations in the area defined in Section 2(1)(d) point 1-14 of the law.

Reports can be made through this IRS to the competent person designated by this IRS or, under the conditions of the whistleblower protection act, to the Ministry of Justice at tel: +420 221 997 111, email: posta@msp.justice.cz (more information at https://justice.cz/ministerstvo-spravedlnosti1) or published under the conditions specified in Section 7(1)(c) of the whistleblower protection act.

3. Competent Person

Name and Surname: Managing director

Position: "Managing director"

Mobile: "+420 732 914 214:

Email: "info@mowio.com"

Data Box:

Activities of the Competent Person:

• Receives and assesses the validity of reports submitted through the internal reporting system,
• Proposes measures to the Company to rectify or prevent unlawful situations based on the submitted reports,
• Follows the Company's instructions, except when they jeopardize or obstruct the performance of their duties under this law,
• Acts impartially in carrying out their duties under this law,
• Maintains confidentiality regarding information learned during the performance of their duties under this law, even after the completion of such activities, unless otherwise provided by law.

The Competent Person shall not be subject to any adverse actions for the proper performance of their duties under this law.

4. Submitting Reports

In accordance with the AML Act, the Company, as an obligated entity under this regulation, accepts anonymous reports. The obligated entity accepts anonymous reports related to violations of any legal regulations, including regulations from any protected area as defined by the whistleblower protection act.

Reports can be submitted through IRS:

1. In writing:

• A: by email to the email address info@mowio.cz,
• B: by mail to the address: Evropská 657/120, Prague 6, 160 00. Please include the text "For the attention of: Monika Lecianova" on the envelope.

2. Verbally:

• A: by phone at the number +420 732 914 214.

 We request that this method of reporting be used during regular working hours (Monday to Friday from 9:00 to 16:00).

3. In person:

• At the request of the whistleblower by prior arrangement. The date of the personal meeting can be arranged by phone (at phone number +420 732 914 214) or by email (at email address info@mowio.cz). The Competent Person is obliged to accept the report in person within a reasonable time (but no later than 14 days from the request).
• The whistleblower may also submit their report through an external reporting system established by the Ministry of Justice (except for reports of violations of obligations under the AML Act) or the Financial Analytical Office.

5. Procedure of the Competent Person after Receiving a Report

If the whistleblower requests it, the Competent Person must personally accept the report within a reasonable time, but no later than 14 days from the date of the request.

The Competent Person is obliged to assess the validity of the report and notify the whistleblower in writing of the results of the assessment within 30 days from the date of receiving the report. In cases that are factually or legally complex, this deadline can be extended by up to 30 days, but no more than twice. The Competent Person must notify the whistleblower in writing of the extension of the deadline and the reasons for it before the original deadline expires.

If, during the assessment of the validity of the report, the Competent Person determines that the report does not fall under this law, they must promptly notify the whistleblower in writing.

If the report is found to be valid, the Competent Person of the Company shall propose measures to prevent or rectify the unlawful situation. If the report is submitted to the Competent Person of the Company for whom the whistleblower does not perform work or any similar activity, the Competent Person shall propose remedial measures to the person for whom the whistleblower does perform work or any similar activity, unless the nature of the matter precludes it. The Company shall promptly inform the Competent Person about the measures taken, and the Competent Person shall notify the whistleblower in writing without undue delay.

If the report is not found to be valid, the Competent Person must promptly notify the whistleblower in writing that, based on the facts stated in the report and the circumstances known to them, there is no suspicion of unlawful conduct or that the report is based on false information, and shall inform the whistleblower of their right to submit a report to a public authority.

6. Sharing of the Internal System and Handling of Whistleblower's Personal Data

The Company is an obligated entity under the AML Act, and therefore, the sharing of the internal reporting system is excluded for it. The Company has its own internal reporting system and its own Competent Person who assesses and proposes remedial measures for received reports.

All information provided through IRS, including personal data obtained directly from the whistleblower, will be treated as confidential and handled in accordance with the whistleblower protection act. Personal data will be processed in accordance with this law, as well as Act No. 253/2008 Coll., on certain measures against the legalization of proceeds from crime and the financing of terrorism, and Act No. 110/2019 Coll. on the processing of personal data.

7. Conclusion

The Company undertakes to train its employees and associates on this VOS and the rights and obligations arising from it. At the same time, the Company undertakes to regularly evaluate this VOS and ensure its effectiveness and compliance with the law.

This VOS shall take effect on 1 August 2023.