We use cookies to enhance your browsing experience, serve personalized ads or content, and analyze our traffic. By clicking "Accept", you consent to our use of cookies. More informations
Notification means an oral or written report by a natural person containing information about possible unlawful conduct that the notifier (whistleblower) has learned about in connection with their work or other similar activities.
Any natural person who reports or discloses information about violations of legal regulations obtained in connection with activities related to their work or other similar activities. Whistleblowers may be:
employees, former employees, job applicants;
volunteers, trainees and interns;
self-employed persons;
persons exercising rights attached to participation in a legal entity;
persons performing functions of a member of a legal entity's body;
persons performing tasks within the scope of the activities of a legal entity, in its interest, on its behalf or on its account;
persons exercising rights and obligations under a contract the subject matter of which is the provision of supplies, services, construction work or other similar performance.
A whistleblower may be also any natural person who has been committed to the Compliance Program of the Obliged Entity and reports a violation thereof.
The obliged entity (the "Obliged Entity") is each of the following companies:
Zeitgeist Asset Management s.r.o., ID No.: 028 61 674, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague under file no. C 224677,
Rav PropCo Rentals I. s.r.o., ID No.: 055 76 741, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague under file no. C 266209,
Rav PropCo Rentals II. s.r.o., ID No.: 069 04 637, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague under file no. C 291063,
Rav PropCo Apartments I. s.r.o., ID No.: 070 83 882, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register kept by the Municipal Court in Prague under file no. C 294410,
Rav PropCo Student Housing I. s.r.o., ID No.: 073 13 870, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register kept by the Municipal Court in Prague under file no. C 298945,
Národní 138/10, s.r.o., ID No.: 283 57 931, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register kept by the Municipal Court in Prague under file no. C 168821,
SPNK 36 s.r.o., ID No.: 092 23 762, with registered office at U půjčovny 952/2, Nové Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague under file no. C 332854.
The protection of whistleblowers is comprehensively regulated by the Czech Act No. 171/2023 Coll., on the Protection of Whistleblowers (the "Whistleblower Protection Act"), in accordance with Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, and Czech Act No. 172/2023 Coll., which amends certain laws in connection with the adoption of the Whistleblower Protection Act.
The content of the notification is information about possible unlawful conduct that:
has the characteristics of a criminal offense;
has the characteristics of an offense for which the Whistleblower Protection Act provides for a fine with an upper limit of at least CZK 100,000;
violates the Whistleblower Protection Act; or
- violates another legal regulation or regulation of the European Union in the areas defined in Section 2(1)(d) of the Whistleblower Protection Act, i.e., in the area of:
Financial services, mandatory audit and other verification services, financial products, and financial markets;
Corporate income tax;
Prevention of money laundering and terrorist financing;
Consumer protection;
Compliance with product requirements, including their safety;
Transport safety, transportation, and road traffic;
Environmental protection;
Food and feed safety and animal protection and health;
Radiation protection and nuclear safety;
Competition, public auctions, and public procurement;
Protection of public order and safety, life, and health;
Protection of personal data, privacy, and security of electronic communications networks and information systems;
Protection of the financial interests of the European Union, or
Functioning of the internal market, including the protection of competition and state aid under European Union law.
Persons who have been acquainted with the Compliance program of the Obliged Entity may also report any conduct that violates the Compliance program.
Notifications can be submitted through the internal notification system of the Obliged Entity, the external notification system through the Ministry of Justice, or by publication, or directly to the competent public authorities.
The whistleblower may submit the notification via the internal notification system exclusively to the Compliance Officer (the competent person) and is entitled to submit it in writing or orally.
The following persons are the competent person to receive notifications ("Compliance Officer "):
[Zdenka Noack], Chief Compliance Officer
[Alena Čermák], Deputy Compliance Officer in the absence of the Chief Compliance Officer
To submit a notification through the internal notification system, the notifier may use:
a written notification, which can be sent to the address of the Obliged Entity, with the envelope marked "Notification - do not open - only to the hands of the Compliance Officer",
e-mail addresses of the Compliance Officer: zdena.noack@zeitraum.re and the Deputy Compliance Officer alena.cermak@zeitgeist.re,
the Compliance Officer's telephone line +420 736 777 214 and the Compliance Officer's representative +420 605 557 183, i.e. every working day from 09:00 to 17:00.
online form on the website www.zeitgeist.re.
personal meeting by prior agreement.
Please provide your name, surname and date of birth or other identifier to verify your identity when submitting your notification. However, the obliged entity also accepts anonymous notifications. The Compliance Officer is bound by confidentiality, and its breach is subject to sanctions.
The Compliance Officer shall inform the notifier of the receipt of the notification within 7 days of its receipt. If the Compliance Officer determines, in the course of assessing the validity of the notification, that it is not a notification under the Whistleblower Protection Act, the Compliance Officer shall notify the whistleblower in writing without undue delay.
The Compliance Officer assesses the validity of the notification within 30 days of its receipt. In factually or legally complex cases, the Compliance Officer may extend this period by up to 30 days, but no more than twice; in such a case, the notifier must always be informed of the extension and its reasons before the original period expires.
The Compliance Officer will then inform the notifier whether the notification has been found to be substantiated or not. If the notification is assessed as substantiated, the Compliance Officer shall propose to the Obliged Entity measures to prevent or remedy the infringement. If the Obliged Entity does not accept the action proposed by the Compliance Officer, it shall take other appropriate action to prevent or remedy the violation.
The Obliged Entity promptly informs the Compliance Officer of the measure taken, who shall inform the notifier in writing without undue delay. If the notification is not found to be substantiated, the Compliance Officer shall inform the notifier in writing without undue delay that, based on the facts stated in the notification and the circumstances known to them, that they did not find any suspicion of unlawful conduct or found that the notification was based on false information and informs the notifier of the right to submit a notification to the competent public authority.
Confidentiality of notification channels is ensured. Information about the identity of the notifier and also the person who provided assistance in obtaining the information contained in the notification, or a person close to the notifier (as defined in Section 4(2) of the Whistleblower Protection Act, hereinafter referred to as "Protected Persons") can only be provided with their written consent unless the relevant person is obliged to provide this information to the competent public authorities under other legal regulations, in which case the notifier and the person concerned will always be informed in advance. The notifier and the Protected Person are entitled to protection against any retaliatory measures by the Obliged Entity.
The notifier may use an external notification system to submit the notification.
The submission can be made via the form of the Ministry of Justice I want to submit a notification - public - Notifier (justice.cz).
A natural person who knowingly submits a false notification is not entitled to protection against retaliatory measures. The notifier commits an offense by knowingly submitting a false notification, for which a fine of up to CZK 50,000 can be imposed.
