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Ethical Commandments

As a member of an international financial group, SGEF adheres to SG Group’s codes, specifically the Group Code of Conduct and the Anti-corruption Code. We expect our business partners to observe the same rules.

WE CONDUCT OURSELVES ETHICALLY AND RESPONSIBLY TOWARDS OUR EMPLOYEES AND THE ENVIRONMENT
  • We adhere to the principles laid down in the SG Group Code of Conduct.
  • We deliver on the commitments undertaken by SG as a responsible Group.
  • We are committed to the protection of human rights and fundamental freedoms, and we guard against any threats to them.
  • We treat all employees fairly and take care to comply with all legal requirements.
  • We protect the health and safety of our employees.
  • The foreign nationals we employ hold permits to reside and work in the Czech Republic where this is required by law. We are committed to environmental protection and sustainable development.
  • We have crisis response procedures and scenarios in place to mitigate any losses we or our business partners may incur.
WE HAVE NO CRIMINAL RECORD AND NO INTERNATIONAL SANCTIONS HAVE BEEN IMPOSED ON US
  • Neither our company nor its assets are subject to any judicial, administrative or arbitration proceedings.
  • The discharge of our obligations under supply contracts is not compromised by any criminal prosecution of our company or members of its governing body.
  • No members of our company’s management are subject to criminal penalties or to measures imposed for reasons of protection or prevention, and none of them has been convicted of a criminal offence in the past.
  • No economic or financial sanctions, trade embargoes or similar measures adopted by the UN, the US, the UK or the EU have been placed on us.
WE PAY VAT
  • We are reliable payers of VAT.
  • The payment we charge for taxable supply is economically justified and consistent with the open market price.
WE FIGHT CORRUPTION
  • We adhere to the SG Anti-corruption Code.
  • We comply with anti-corruption legislation in all cases.
  • We do not engage in conduct that might be construed as corruption or bribery.
  • No authority has disqualified us from participating in public tenders on grounds of corruption or bribery.
  • We apply rules and processes to safeguard against corrupt practices and to ensure that any suspected corrupt practices are investigated with due diligence.
  • We maintain detailed and meticulous accounting, files and other records related to supply contracts.
  • We do not accept or offer any special privileges or gifts of any kind.
CONFIDENTIAL INFORMATION AND PERSONAL DATA ARE SAFE WITH US
  • We hold confidential information in strict confidence.
  • We use confidential information, know-how, databases and business information solely within the framework of contractual cooperation and do not exploit it for our personal or third-party gain.
  • We adhere to all legislation governing the protection of the personal data of our clients, employees and contractual partners.
  • We handle personal data in a manner that precludes unauthorised access and processing, alteration, destruction, loss or misuse.
WE HAVE ZERO TOLERANCE OF MONEY LAUNDERING AND TERRORIST FINANCING
  • We comply with obligations imposed on us by the Ant-money Laundering and Terrorist Financing Act.
  • We are not a politically exposed person, as defined by that law.
  • We thoroughly screen prospective customers, conduct ongoing checks, report suspicious transactions in a timely manner, provide staff training, and maintain a system of internal policies.

Whistleblowing notices

This page enables a whistleblower to inform SGEF of facts of which he/she has become aware directly or indirectly in the course of his/her work or other similar activity and which are contrary to legal regulations, internal regulations or ethical principles, or which he/she himself/herself has been the target of inappropriate behavior (hereinafter referred to as "Whistleblowing alert"). Persons not falling under the above definition of a whistleblower may also make a Whistleblowing alert.

Personal data, if obtained from the whistleblower, are processed only for the purpose of evaluating the relevance and resolution of a specific Whistleblowing alert, the legal basis for the processing of personal data is the fulfilment of a legal obligation by SGEF under the wording of Act No. 171/2023 Coll., on the Protection of Whistleblowers.

There is no transfer of the collected personal data to third parties, only the exclusive recipients (the so-called Competent Persons, see contacts below) are the recipients. The personal data will be archived for a period of 5 years from the date of receipt of the alert.

Further information regarding the processing and protection of personal data, including the exercise of your rights, can be found on SGEF's website.

Who is whistleblower

A person who performs or has performed work or other similar activity for SGEF, which means:

  1. Dependent work performed in an employment relationship
  2. Self-employment
  3. Exercise of rights connected with participation in SGEF
  4. Performance of tasks within the scope of the activities of a legal entity, in its interest, on its behalf or on its account
  5. Volunteer activities
  6. Professional practice, internship
  7. Exercise of rights and obligations arising from a contract the subject of which is the provision of supplies, services, works or other similar performance.

Work or other similar activity includes applying for a job or other similar activity.

How to blow the whistle

Whistleblowing alert can be made:

1. Via the dedicated SGEF notification email account - oznameni@sgef.cz 

2. Through group whistleblowing system of Société Générale (SGEF's  parent company), if the internal whistleblowing system of SGEF is not suitable or cannot be used –  https://report.whistleb.com/en/portal/socgengroup 

3. To the Competent Persons listed below, with whom you can arrange a personal meeting if necessary:

  1. Marcela Nouzová, Compliance Specialist, +420 602 950 533
  2. Petr Kupsa, Compliance Specialist, +420 720 953 130
  3. Tomáš Choutka, Head of Regulatory Compliance, +420 602 575 927

(hereinafter collectively referred to as "Competent Persons" or "Competent Person")
Common e-mail address of the Competent Persons: oznameni@sgef.cz  

4. In writing

To the address of the company at the hands of the Competent Person

SG Equipment Finance Czech Republic s.r.o.
nám. Junkových 2772/1
Praha 5 150 00

indicate on the envelope "Whistleblowing - DO NOT OPEN"

For the purpose of further communication, please include your name, surname, date of birth or other information proving your identity in the Whistleblowing alert.
You may also make your Whistleblowing alert anonymously.

What are the next steps?

The whistleblower shall receive written confirmation of receipt of the Whistleblowing alert within 3 working days of its receipt at the latest. At the same time, the whistleblower will be informed whether or not his/her notification falls under the definition of notification pursuant to Act No 171/2023 Coll., on the Protection of Whistleblowers (hereinafter referred to as the "ZoOO") and what rights and obligations he/she is entitled to within this process. The information provided will be treated as strictly confidential.

The Competent Person will proceed with the investigation in such a way that the identity of the whistleblower is not disclosed. At all times during the investigation, the identity of the whistleblower will be known only to the Competent Persons. In the event that it is not possible to proceed with the investigation without disclosing the identity of the whistleblower to other persons, the Competent Person shall inform the whistleblower of this and seek his/her explicit consent to this procedure.

This does not apply in cases where the identity of the whistleblower is requested by public authorities. However, the Competent Person must inform the whistleblower of this fact in advance, together with the reasons for which it is obliged to provide the identity information, and give the whistleblower the opportunity to comment on the provision of the information.

The investigation will then assess the reasonableness of the Whistleblowing alert and other relevant facts. The Competent Person will then inform the whistleblower in writing of the results of this assessment within 30 days of receipt of the Whistleblowing alert. Where the matter is factually or legally complex, the Competent Person may extend this period by 30 days, up to a maximum of twice. In such cases, the Competent Person must always inform the whistleblower of the extension and the specific reasons for it.

No acts of retaliation will be taken against the whistleblower if the Whistleblowing alert is made in good faith and without expectation of financial consideration. If the Whistleblowing alert meets the definition under Section 2(1) of the ZoOO, the whistleblower will be subject to the protections of this Act. In such a case, the Whistleblowing alert may also be made through the external notification system established by the Ministry of Justice. This does not apply in the case of facts that fall under the scope of Act No. 253/2008 Coll., on Certain Measures Against The Legalization of Proceeds of Crime And Terrorist Financing, where the competent authority for dealing with the notification is the Financial Analytical Office.

If your notification or enquiry relates to another area, you will be redirected to another responsible department of SGEF.