COMPLIANCE
at Alza.cz a.s

To fulfill the core principles of the Company based on the Anti-Corruption Policy Directive, Alza.cz allows for reporting of illegitimate, unethical, or illegal practices through the means outlined below.

 

You can reach out via email at [email protected].

 

This channel is managed by a specific designated person, currently the Chief Compliance Officer (CCO), represented by Pavla Vrbková. The CCO can be directly contacted at phone number +420 778 746 890 or email [email protected].

You can also file a report with the Ministry of Justice. 

 

All relevant reports will be investigated thoroughly, and the notifier will be contacted as needed according to legal procedures. The person who investigates the report will keep the notifier's identity confidential.

 

Please note that this email address is not for customer support inquiries (orders, complaints, etc.). For customer support, please use https://www.alza.cz/contact.

KYC from of Alza.cz a.s.

   

Table of Contents

• Declaration
• Article 1: Purpose and Scope of the Anti-Corruption Policy Directive
• Article 2: Definition of Basic Terms
• Article 3: Company Responsibility and Key Employee Obligations
• Article 4: Anti-Corruption Policy and Listing of Fundamental Principles
• Article 5: Zero Tolerance Principle
• Article 6: Due Diligence Principle
• Article 7: Education Principle
• Article 8: Transparency Principle
• Article 9: Prevention, Detection, and Response Principles
• Article 10: Conflict of Interest Prevention Principle
• Article 11: Rules for Giving and Receiving Gifts and Hospitality
• Article 12: Business Conduct and Procurement Procedures
• Article 13: Control Measures for Directive Compliance and Ethics Hotline
• Article 14: Accessibility and Interpretation of the Directive
• Article 15: Effectiveness of the Directive

Declaration

Alza.cz a.s. (hereafter referred to as "Company") embraces this Anti-Corruption Policy Directive, which elaborates and specifies the principles contained within the Code of Ethics.

This directive, akin to the Code of Ethics, applies to individuals acting within or in the interest of the Company, irrespective of their role or job classification.

Adhering to the standards of the Code of Ethics and this directive is considered an integral part of the corporate culture.

Article 1
Purpose and Scope of the Anti-Corruption Policy Directive

1. The Anti-Corruption Policy Directive (Directive) establishes fundamental principles and specific rules for preventing and combating corruption at Alza.cz a.s. (the Company). It applies to all employees of the Company, as well as business partners and other individuals acting in the interest of or within the scope of the Company's activities.
2. The purpose of the Directive is to promote fair, honest, just, and transparent business practices of the Company in accordance with the legal framework of the Czech Republic, international agreements, and internal regulations of the Company.
3. The Directive applies notably to all individuals whose criminal conduct as defined by Act No. 40/2009 Coll., the Criminal Code (hereafter referred to as "Criminal Code"), could be attributed to the Company within the meaning of § 8 of Act No. 418/2011 Coll., on Criminal Liability of Legal Entities and Proceedings Against Them (hereafter referred to as "Criminal Liability Act").

Article 2
Definition of Basic Terms

1. Corruption offenses within the scope of this Directive encompass all criminal acts that involve actions aimed at using or abusing power or position for the purpose of gaining unauthorised benefits (hereafter also referred to as "corrupt actions"). This notably includes bribery offenses, such as acceptance of a bribe (§ 331 of the Criminal Code), bribery (§ 332 of the Criminal Code), indirect bribery (§ 333 of the Criminal Code), as well as the following criminal offenses: organ or tissue trafficking and transplantation for remuneration (§ 166 of the Criminal Code), conspiracy in insolvency proceedings (§ 226 of the Criminal Code), violation of rules on economic competition (§ 248 para. e) of the Criminal Code), securing an undue advantage in public procurement, public competition, and public auction (§ 256 para. 1 and 3 of the Criminal Code), conspiracy in public procurement and public competition (§ 257 para. 1 of the Criminal Code), conspiracy in public auction (§ 258 para. 1 of the Criminal Code). Additionally, criminal offenses exhibiting signs of corrupt behavior in certain specific situations may include fraud (§ 209 of the Criminal Code), insurance fraud (§ 210 of the Criminal Code), credit fraud (§ 211 of the Criminal Code), subsidy fraud (§ 212 of the Criminal Code), operating dishonest games and betting (§ 213 of the Criminal Code), breach of duty in the administration of another's property (§ 220 of the Criminal Code), breach of duty in the administration of another's property through negligence (§ 221 of the Criminal Code), misuse of information in business transactions (§ 255 of the Criminal Code), abuse of position in business transactions (§ 255a of the Criminal Code), and interference with judicial independence (§ 335 of the Criminal Code).
2. Criminal liability for corruption offenses may arise in cases of attempted corrupt actions or their preparation, i.e., by merely creating relevant conditions for the commission of a corrupt criminal offense.
3. Criminal liability for corruption offenses may arise for participation in corrupt actions in the form of aiding (facilitating or enabling corrupt actions) or abetting.
4. A bribe refers to any undue advantage resulting in pecuniary enrichment or other (including non-pecuniary) benefits granted to the bribed person or another person with the consent of the bribed person. A bribe may encompass any monetary or non-monetary consideration (provided directly or indirectly) for which there is no legal entitlement and whose usual purpose is profit or maintenance of business, other than through one's own activities and economic performance, or the influence of commercial or other decisions, or the securing of any other unauthorised advantage.
5. Conflict of interest denotes a situation in which personal interests conflict with interests that the subjects of these personal interests must promote or defend by virtue of their position or function. Personal interest refers to an interest that provides personal benefits to its subject or prevents potential decrease in pecuniary or other benefits.

Article 3
Company Responsibility and Key Employee Obligations

1. The Company does not tolerate any corrupt actions and violations of this Directive. All employees are aware that their decisions and actions may expose both themselves and the Company to criminal, administrative, civil, or employment penalties for corrupt criminal offenses, even in the case of unsuccessful realisation or preparation thereof.
2. Employees have a primary obligation to avoid any actions that could be perceived as corrupt or could qualify as a corrupt criminal offense. They must act in a manner that does not give rise to suspicion of corrupt behaviour.
3. Employees are prohibited from engaging in relations in which they have a conflict of interest. They must take steps to prevent situations that raise doubts about a potential conflict of interest and, if necessary, promptly report such potential conflict to the Chief Compliance Officer (CCO).

Article 4
Anti-Corruption Policy and Listing of Fundamental Principles

1. The Company establishes an environment where any corrupt conduct is rejected and promotes honest and ethical behavior aimed at protecting the Company's reputation and assets.
2. The Company unequivocally opposes any acceptance or offering of bribes, regardless of form or means of provision. It fosters an environment where transactions are never conducted without legal or economic justification, or without legal basis.
3. Employees are required to act in a transparent manner and avoid any actions that could be perceived as corrupt.
4. Employees are obliged to rigorously avoid any conflict of interest.
5. Violation of the anti-corruption policy expressed in this Directive will be deemed a serious breach of internal rules and values, and may result in termination of contractual (especially commercial, contractual, employment-related) relations with the Company or lead to criminal liability.
6. This Directive is based on the following principles:
   1. Zero tolerance principle;
   2. Due diligence principle;
   3. Education principle;
   4. Transparency principle;
   5. Prevention, detection, and response principles;
   6. Conflict of interest prevention principle.

Article 5
Zero Tolerance Principle

1. The Company enforces a zero tolerance principle towards all forms of corrupt conduct.
2. Employees are explicitly prohibited from inciting, concealing, distorting, tolerating, accepting, or trivialising any corrupt conduct within the Company. Additionally, they are prohibited from demanding or accepting any payments, services, benefits, or remunerations that contradict the provisions of this Directive or any other internal regulations of the Company.

Article 6
Due Diligence Principle

1. In situations where there is a risk of corrupt conduct, employees are obliged to act with due care and diligence.
2. Employees must exercise particular caution and prudence in legal relationships where there is an elevated risk of corrupt conduct.
3. If doubts arise about the existence of risks or uncertainty about the legal or economic nature, employees are required to consult their supervisor or the head of the compliance team. Records of events reported to the head of the compliance team and their resolution are maintained by the compliance team.

Article 7
Education Principle

1. Employees are required to undergo training regarding the principles, rules, and procedures within the Company's anti-corruption strategy as part of their initial training.
2. The training covers not only legal knowledge but also insights into model situations where there is an elevated risk of corrupt conduct.
3. As part of the Company's anti-corruption strategy, employees attend regular training sessions. The scope and nature of these sessions depend on their job classification and position within the Company.
4. Records of completed employee training are maintained in either written or electronic form. The Human Resources department (HR) keeps track of completed training.

Article 8
Transparency Principle

1. The Company establishes a transparent environment within its anti-corruption strategy.
2. Transparency is not only promoted internally, i.e., among Company employees, but also externally, i.e., in relationships with business partners, individuals acting on behalf of the Company or within its operations, and customers. It ensures that the Directive and other key internal regulations related to the anti-corruption strategy are accessible to the public.
3. The Company acquaints not only its employees but also business partners and individuals acting on behalf of the Company or within its operations with the Directive.

Article 9
Prevention, Detection, and Response Principles

1. The Company creates the necessary infrastructure for the effective functioning of the compliance team. The compliance team consistently identifies corruption indicators among legal entities and individuals.
2. The specific aim in this area is to minimize losses caused by corrupt conduct and prevent the recurrence of similar corrupt behavior. In such cases, the compliance team analyses the root causes of corrupt conduct to enhance preventive mechanisms that reduce the risk of repeated corrupt behaviour.
3. The measures must ensure that employees have the right to submit complaints, suggestions, recommendations, and other submissions pointing out actions contrary to legal regulations or internal Company policies.
4. Each executive employee is obligated to evaluate the fulfillment of obligations arising from anti-corruption measures, the effectiveness of their implementation, the execution of corrective measures, and, if necessary, propose updates to this Directive or other anti-corruption measures or internal Company regulations.
5. In collaboration with the compliance team, the Company's management declares its readiness to undertake appropriate corrective measures upon the identification of any misconduct, depending on the severity and nature of the incident.
6. Corrective measures, as defined in the previous point, encompass:
   1. Amendments to internal Company regulations,
   2. Imposition of disciplinary actions, or
   3. Addressing incurred damages and informing employees about steps taken in relation to confirmed corrupt or illegal conduct, including assigning responsibility for the damages.
7. No employee shall face any form of punishment (disciplinary, employment-related, financial, etc.) for reporting suspicions of corruption, seeking consultation in this matter, proposing measures or changes to regulations within the anti-corruption strategy, or refusing a bribe. This applies even if the Company loses a business opportunity as a result of such actions.

Article 10
Conflict of Interest Prevention Principle

1. Conflicts of interest are a risk factor that must be prevented in anti-corruption measures.
2. Any conflict of interest, even if potential, is strictly prohibited. Even the slightest conflict of interest must be reported to a superior or the head of the compliance team.
3. In the realm of business activities, employees are primarily accountable to the Company and must refrain from any actions that could, even seemingly, interfere with fulfilling this responsibility.
4. Employees are specifically prohibited from:
   1. Entering relationships in which the employee knows or at least suspects that their personal interest conflicts with the Company's interest,
   2. Being responsible for business transactions that constitute a conflict of interest, or being personally involved in business dealings in a way that could compromise their objective and impartial judgment,
   3. Providing orders, contracts, or services to the Company to relatives, employees' close associates, or friends without supervisor approval,
   4. Entering binding relationships, including employment agreements, engaging in business ownership, or collaborating with Company business partners,
   5. Exploiting the Company's business relationships, contacts, data, and other information for personal gain or the gain of a third party,
   6. Withholding, distorting, or downplaying any personal, family, or employment relationships and connections that could negatively impact transparent and fair business relations.
5. The existence of a potential conflict of interest does not automatically exclude a third party from relations with the Company. However, if a conflict of interest arises between the Company and an employee's personal interest, the party in question must not prioritise their personal interest over the interests they are obligated to promote and defend as a Company employee. Simultaneously, it must be apparent to all that this third party has not gained any unauthorised advantage due to their relationship with Company employees. Therefore, for situations in which a conflict of interest is imminent, the following procedures are established:
   1. Employees are required to report situations leading to actual or perceived conflicts of interest to their superiors or the head of the compliance team,
   2. The superior or head of the compliance team is then responsible for resolving the actual or perceived conflict of interest,
   3. Individuals facing a conflict of interest must not participate or be otherwise engaged in decisions affected by the conflict,
   4. Resolution of a conflict of interest must be adequately documented in written or electronic form.

Article 11
Rules for Giving and Receiving Gifts and Hospitality

1. The giving and receiving of gifts and hospitality is a generally accepted practice for building positive social relationships, but only under specific conditions that limit the risk of corrupt conduct associated with these activities.
2. Offered benefits must always be modest, transparent, serve a purpose that aligns with the law and the Company's interests, and should be given consistently and without exception.
3. Employees are allowed to retain a gift under the following conditions:
   1. The total value of the gift does not exceed 1,000 CZK (including VAT);
   2. The gift consists of perishable items such as food and beverages or other products with a short expiration date;
   3. The gift is of an advertising nature, clearly marked with the giver's logo.
4. When an employee is offered a gift that doesn't meet the Company's internal rules, it is mandatory to promptly inform the appropriate person (their superior or the head of the compliance team) following the Company's internal regulations.
5. Except for cases specifically permitted in writing by the Company's board, employees are not allowed, in particular, to accept gifts in the form of stays, trips, outings, or invitations to cultural, sporting, or other social events.
6. Employees must not promise, offer, or provide monetary, financial, or material gifts to Company business partners or third parties without any contractual or legal entitlement.
7. The act of giving a gift must be in accordance with the Company's internal regulations.
8. Employees may donate tangible gifts (goods) of the Company for pre-approved competitions or other events. However, such donations must be carried out based on a written agreement approved by a responsible director.

Article 12
Business Conduct and Procurement Procedures

1. In all business transactions and within procurement procedures, employees are obligated to uphold equal access, transparency, and avoid any form of discrimination, while adhering to the Procurement Directive.
2. Business partners and individuals acting on behalf of or within the scope of the Company must maintain credibility and solvency throughout the entirety of their relationship with the Company, and share the same ethical and moral values in relation to the Company's anti-corruption strategy.
3. All contracts with business partners and individuals acting on behalf of or within the scope of the Company must include an anti-corruption clause. This clause states that the concerned individual is acquainted with this Directive and shares the same ethical and moral values regarding the Company's anti-corruption strategy, and commits to refraining from any conduct contrary to the anti-corruption clause.

Article 13
Control Measures for Directive Compliance and Ethics Hotline

1. To ensure effective compliance monitoring of this Directive, the Company has established a system that allows both employees and third parties to submit notifications, including anonymously.
2. The Company processes received notifications regardless of the notifier's identity or the chosen method of submission. The act of submitting a notification is not subject to any sanctions from the Company. The Company only rejects malicious or knowingly false reports.
3. Notifications that the notifier considers as such can be submitted through one of the following methods:
   1. Direct communication with the Chief Compliance Officer (CCO);
   2. Using the ethics email provided on the Company's website and, if applicable, on its intranet [email protected];
   3. Via an anonymous mailbox.

Article 14
Accessibility and Interpretation of the Directive

1. The Anti-Corruption Rules Directive is approved by the Company's board and is published on the Company's intranet and a publicly accessible location on the Company's website. The contained rules may be further specified within the Company's internal regulations or guidelines provided by responsible employees.
2. When interpreting the principles and rules contained in this directive, the essence and purpose of these must be taken into account.

Article 15
Effectiveness of the Directive

This Directive becomes effective on September 29, 2022.