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Compliance and Privacy

Our Company has a long tradition, many successfully completed projects and satisfied customers. Our Compliance program sets the highest ethical standards against any potential risk of corruption or bribery. The Company's management unreservedly supports these ethical standards and openly declares zero tolerance for corruption in any form and requires unconditional compliance with ethical standards from its employees and contractual partners.
Member of the Board of NVision

 

The Company strictly adheres to the principles of compliance with applicable Anti-corruption legislation and ethical conduct in all types of business relationships and regardless of the territory the Company operates in. The Company expects all persons acting on behalf of or in the interest of the Company to adhere to the applicable Anti-corruption legislation. Therefore, the Company has introduced the Compliance Program, an integral part of which is the Code of Business Conduct and Ethics, Anti-Corruption Policy and Managing the Conflict of Interest Policy. Links to these main compliance documents are available below.

 

  

CODE OF BUSINESS CONDUCT AND ETHICS

The Code is the main document of the Company that contains the key principles of business conduct and sets up standards and requirements adopted by our Company in order to comply with relevant laws, honest, fair and ethical business practices and prevent indecent practices. The Company does not use any business practices in breach of these rules and standards..

Code of Conduct NVision Czech Republic a.s.



ANTI-CORRUPTION POLICY

This Policy establishes key principles and requirements for compliance with the applicable anticorruption legislation, defines the areas of corruption risks and establishes approaches to their overcoming and/or mitigation at the Company. The Policy addresses the risks of bribery and corruption in both the public and private sectors.

By implementing this Policy, the Company sets the following goals:

·           to establish the standards of responsible business behavior, to implement and develop best corporate governance practices;

·           to demonstrate the Company's commitment to the principles of legality, transparency and social responsibility;

·           to outline the principles aimed at preventing any form of corruption and compliance with the requirements of the Applicable Anticorruption Legislation in the course of conduction of business activity by the Company;

·           to raise the level of corporate compliance culture in the Company, as well as to raise awareness of the risks of corruption and to assist in clarifying and observing the rules.

Anti-corruption Policy - English version

 


ANTI-CORRUPTION TRAINING FOR THIRD PARTIES

For many companies, the cooperation with third parties is critical. By using the skills and resources of third parties a company can grow its business, access new markets and harness innovation and resources. It can also leverage its influence and core strengths to energize its third parties to grow and contribute to this process.

That said, reliance on third parties brings risks. Companies are increasingly dependent on others and face a significant challenge in controlling the multiple dimensions of their businesses. While they are benefiting increasingly from concentration of the supply chain on critical third parties, this also increases vulnerability to risks such as bribery and corruption, disruption to continuity of operations, environmental or labor concerns and legal or reputational damage.

To protect against risks, companies must choose their third parties with care, ensure they operate to required standards and monitor their performance. The challenge is how to select, manage and monitor a third party population of diverse companies and to identify, understand and mitigate the truly relevant risks.

Our Company follows the principles of compliance with anti-corruption laws in all business relationships.

With this Anti-corruption training NVision encourages and requires Third Parties we do business with to follow the same anti-corruption principles and standards as the basis of our mutual success. This training will provide you information what does it mean for your daily business with our Company.

We value your partnership and thank you for taking time to complete this informational training program.

Anti-corruption Training for Third Parties



MANAGING CONFLICTS OF INTEREST POLICY

This Policy establishes the basic principles for managing the Conflicts of Interest at NVision Czech Republic a.s (hereinafter referred to as the “Company”), and also defines measures aimed at preventing and minimizing the consequences of Conflicts of Interest in order to enhance confidence with the Company on the part of stakeholders (shareholders, investors, Employees, Customers, Counterparties, etc.).

By implementing this Policy, the Company sets the following goals:

  1. establishment of a unified system for managing Conflicts of Interest within the Company;
  2. determination of the rules of conduct in cases of Conflicts of Interest;
  3. consolidation of measures aimed at preventing and minimizing the consequences of Conflicts of Interest;
  4. compliance of the Company with international standards and best practices in order to enhance the Company goodwill, including internationally.
 

The Policy is binding on contractual partners/Counterparties of the Company to the extent provided for by contracts concluded with such persons/entities.

 

Counterparties may declare Conflicts of Interest that are detriment to the interests of the Company and (or) violate the Applicable Anticorruption Legislation by sending information about them to the Unified Hotline (www.oznam.to) and (or) by notifying the contact persons of the Company authorized to interact with this Counterparty under the contract through the means of communication, according to the form and within the terms specified in the contract. Disclosure of Conflicts of Interest Form is available to contractual partners.

Oznámení střetu zájmů

Disclosure of Conflicts of Interest

Politika Řízení střetu zájmů

Policy Managing Conflicts of Interest

Role a odpovědnost při řešení střetu zájmů

Roles and responsibilities in Managing Conflicts of Interest


 
 

UNIFIED HOTLINE

To report possible or committed violations of the provisions of the Code of Business Conduct and Ethics, corruption, fraud and other violations of the law related to the Company's operations, you can contact the Unified Hotline in one one of the following ways:

(1) via an electronic form on the website www.oznam.to;

(2) via written notification sent to the external partner, company Lexnova s.r.o., Na rovnosti 12, 130 00 Prague 3, Czech Republic (including anonymously);

(3) by phone: + 420 317 079 804.

 

When receiving and assessing notifications, the Company guarantees the confidentiality and non-disclosure of personal data of those who have made a notification. The Company also prohibits any form of prosecution (retaliation) against persons who have reported a breach in good faith. You can also report violations anonymously. However, providing deliberately false or misleading information is not permitted.

 

Compliance manager NVision Czech Republic: e-mail compliance@nvisioncz.com


  

An important statement regarding your privacy

By reading the following text, you are to be informed about the data collection we practice, as well as about your rights connected to the usage of personal information.

 

Data collector contact

NVision Czech Republic a.s., headquartered at Klášterní 1009, 259 01, Votice, Czech Republic, VAT No. 475 50 937, registered in the Municipal court in Prague Trade Register, sector B, file 10436 (from this point on referred to as „data collector“). Data collector contact e-mail – GDPR@nvisioncz.com.

 

Below, you are to be informed about the kinds of personal information we collect, the reason which it is collected for, the legal footing for the data collection, as well as the duration of this process based on the position you are in relative to the data collector.

If you are a guest visiting our website, we collect and store your IP address with the intention of tracking the number of users, as well as their product preferences, for the period of one day.

 

In case you are a business contractor of our company, we collect your first and last name, your telephone number, and the e-mail address of the person responsible for the internal evidence of contractors for the period of the contract’s duration.

If you are a potential business contractor of our company, we collect the first and last name of all people responsible for the contact with our company, and additionally also all information available in the public registers in order to verify the contractor’s compliance, all of the mentioned being collected for the entirety of the contract’s duration.  

In the event you are a job applicant for a position in our company, we collect your first and last name, telephone number, e-mail address, and additionally also any other data provided inside your CV/resumé in order to enclose the employment contract or the work agreement, all of the mentioned being collected for the duration of the tender, or else based strictly on your consent.

Your personal data is always to be collected only in the required amounts and for the time period necessary in order to serve the designated purpose.

 

Additional information about data collection

Your personal data is collected manually by the collector’s employees.

Furthermore, the personal data is not to be collected by other data collectors or any subjects other than the ones mentioned above, and is also not to be provided to any third-party subjects or other possible recipients.

Providing your personal data is voluntary.

Sharing your personal data with third parties or countries

Your personal data is not to be shared with any third party, country or international organization.

 

Automated individual decision-making and profiling

Your personal data is not to be subject to any automated decision-making or profiling.

  

INFORMATION ABOUT RIGHTS OF DATA SUBJECTS:

 

Regarding your personal information, you are primarily subject to the following rights: 

  • the right to correct or add your personal data;
  • the right to require processing limitations in the events specified by legal norms;
  • the right to complain or object against processing in the events specified by legal norms;
  • the right to transfer your personal information in the events specified by legal norms;
  • the right to access your personal information;
  • the right to be informed about any violations of personal information security in the events specified by legal norms;
  • the right of personal data deletion;
  • other rights provided by the legal norms.

SUBCONTRACTORS

For the purpose of fulfilling the obligation stipulated by the agreement with NVision Czech Republic a.s. to agree in writing on the list of organizations involved by you to perform work and or provide services in pursuance of your agreement with NVision CzechRepublic a.s. (i.e. subcontractors).

 

The following information about such subcontractors must be sent to the contact person of NVision Czech Republic a.s. under the agreement.

 

·         the subcontractor interacts with the Public Official on behalf of or in the interests of NVision Czech Republic a.s.;

·         the subcontractor is affiliated with the Public Official;

·         the subcontractor has committed a violation of Applicable Anti-Corruption Laws (if such information is available from reliable sources)

 

Please use the following Forms to provide the information on the subcontractors:

 

·         Subcontractors information request Form – NVision Czech Republic a.s. (Czech Version)

·         Subcontractors information request Form – NVision Czech Republic a.s. (English Version)


The key principles of interaction between NVision Czech Republic a.s. and counterparties are set out in the Code of Business Conduct. You can familiarize yourself with the current version of the Code in the text above.