Whistleblowing is considered an effective tool to detect unethical or illegal conduct within a private or public organization. This may include, for example, corruption, abuse of power, violations of workers' rights or harmful impacts on public health and the environment.

Whistleblowing does not mean to snitch on someone. In translation, the term can be understood as “to blow a whistle”, which means warning of something unfair that needs to be paid close attention and checked.

Our company ensures compliance with ethical behavior and does not tolerate any forms of anti-social activity.

The conditions for providing protection to persons in an employment law or other similar relationship in connection with reporting crime or other anti-social activity (hereinafter referred to as "anti-social activity") and the rights and obligations of persons when reporting anti-social activities are regulated by Act No. 54/2019 Coll. on Protection of Whistleblowers of Anti-Social Activity and on Amendments to Certain Acts (hereinafter referred to as the "Act").

Procedure for human rights and environmental concerns

⭢ Complaints mechanism

1. What is anti-social activity and what is considered serious anti-social activity?

The term anti-social activity can be understood (art. 3 letters b) and c) of Act no. 583/2008 Coll. on crime prevention):

  • conduct which constitutes a criminal offence, or
  • conduct which constitutes an offence or an administrative offence, or
  • other conduct that is not an offense or other administrative offence, but acts negatively on society.

Serious anti-social activities are:

  • group of offences determined by the Act (a list of these offences can be found in Section 2, letter d) point 1 of the Act),
  • an offence for which the Criminal Code provides for a maximum term of imprisonment exceeding two years;
  • an administrative offence punishable by a fine with an upper limit determined by calculation, or
  • an administrative offence punishable by a maximum fine of at least €30,000;
2. Who is a whistleblower under the Act?

A notifier is a natural person who, in good faith, makes a notification to the authority competent toreceipt of the notification or to the employer. A notifier shall be considered to be a natural person who:

  • makes a notification and his/her employment relationship or other similar relationship ends, if he/she becomes aware of information about anti-social activity during the duration of that employment relationship or other similar relationship;
  • makes a notification and his/her employment relationship or other similar relationship has not yet arisen if he/she became aware of information about anti-social activities during the selection procedure or in the framework of pre-contractual relations;
  • made the announcement anonymously and his/her identity was revealed;
  • has published information on anti-social activities that it has become aware of during the selection procedure or in the context of pre-contractual relations and its employment relationship or other similar relationship has not yet arisen.

Another similar relationship is considered to be the activity of a self-employed person, the activity of a person acting as a member of the body of a legal entity, the exercise of participation, administration and management rights of a legal entity, the activity of a contractor, voluntary activity, graduate practice, activation activity, professional experience.

3. Possibilities of whistleblower protection

A. Prevent retaliation (preventive protection)

Whistleblowers may ask the public prosecutor or administrative authority for protection, the so-called protected whistleblower status, in the case of a so-called qualified report. In practice, this means that an employer may not perform employment acts or issue a decision in an employment relationship against an employee or a person in a similar relationship in this position without the consent of the Whistleblower Protection Office.

  • requested by the whistleblower when submitting a qualified notification
  • protection is granted by the investigating body
  • it is active from delivery to the employer
  • subsequently, the consent of the Whistleblower Protection Office is required for each legal act

B. Suspend retaliation (follow-up protection)

If the retaliatory measure has already been carried out, the whistleblower may contact the Whistleblower Protection Office within 15 days from the day on which he became aware of the employment act/other similar act and request the suspension of the measure.

  • requested by the whistleblower within 15 days
  • the Whistleblower Protection Office decides whether to suspend them
  • is active by delivery to the employee
  • the employment act is "frozen" for 30 days, followed by the filing of an application for interim measures

C. Protection is provided:

  • To the whistleblower and a close person,
  • To the Compliance Officer and the person who assisted with the notification,
  • To the natural person-entrepreneur or legal entity controlled by the whistleblower, in which he participates, in which he performs the function of a member of an organ of a legal entity, or for which he/she performs employment activities,
  • To the natural person-entrepreneur or legal entity who controls a legal person, in which the whistleblower has a participation or in which he/she performs the function of a member of the body of the legal entity.
4. Forms of submitting notifications

Our company allows its employees and persons in a similar relationship to submit a notification of facts that they have become aware of in connection with an employment relationship or other similar relationship and that relate to anti-social activities.

The notification may be made to the Compliance Officer by:

  • Internal channels:

- Email: FMB_Compliance_office@t-systems.com (non stop 24/7)
- In person
(it is necessary to arrange a meeting with the compliance officer in advance)

- By post to the address of the registered seat
of the company  (mark as "Confidential" on the envelope):

   Compliance, Data P
rivacy and Legal department

   Business name of the company (Deutsche Telekom Systems Solutions Slovakia s.r.o. alebo Deutsche Telekom IT & Telecommunications Slovakia s.r.o.)

   Moldavská cesta 8B, 04011 Košice

- Electronically through DTAG whistleblower Tell me portal (BKMS) - non stop 24/7
   Your notification will be treated in the strictest confidence. If you are concerned about giving your name, you will be able to submit a notification anounymously. The IT system         used for this is certified and provides the necessary technology to ensure that the anonymity of our whistleblowers is fully guaranteed at all times.

  • External channels:

- Whistleblower Protection Office – the reporting form is available on the website https://www.oznamovatelia.sk/chcem-oznamit)
- A law  enforcement authority
(public prosecutor's office / administrative authority competent to issue fines / competent institution of the European Union) in case there is a suspicion of a criminal offence

Submitting notification to the Compliance officer of our company, the obligation to report a crime or prevent a crime under § 340 and § 341 of Act no. 300/2005 Coll. Criminal Code is not affected.

5. What must the notification contain?

The notification must be legible, comprehensible and worded in such a way as to make it clear what the anti-social activity is.

6. Internal system for verification of notifications

The Compliance Officer of the Compliance Department performing the tasks of the employer shall register the notification, acknowledge receipt of the notification within 7 days of its receipt, verify its content and, in the case of anti-social activity notification, notify the whistleblower within 90 days of confirmation of the outcome of the verification and, where appropriate, the action taken.

The referral of the case for settlement under special regulations is also considered to be the verification of the notification. In these cases, we will request the result of the settlement and notify the notifier within 10 days of receipt.