Compliance program

CZG - Česká zbrojovka Group SE

CZG - Česká zbrojovka Group SE (hereinafter referred to as “CZG”) is, together with its subsidiaries, one of the leading manufacturers of firearms and tactical accessories operating worldwide. 

Our company is fully aware of its responsibility for the positive development of the society and conducts its activities strictly in compliance with the laws in force in all territories of its operations. In addition, it meets its obligation to strictly comply with the principles and rules of moral conduct, ethics, fair competition, cooperation, social solidarity and, last but not least, environmental protection and sustainable development.

In order to put these principles and rules in place, we have adopted our Compliance Program which ensures that the relevant rules are implemented throughout the company.

Thanks to the Compliance Program, the rules penetrate the actual company operations and are used as precautionary measures intended to prevent any conduct in violation of the law and the declared principles and rules as well as repressive measures intended to define the consequences of undesirable conduct in a comprehensible form.

The Code of Ethics is the cornerstone of the Compliance Program and a versatile guidance defining the elementary standards of conduct. The rules set out in the Code of Ethics must be kept in mind as the starting points, especially when facing moral dilemmas. Individual elements of the Code of Ethics are apparent in all subsequent instruments of the Compliance Program such as the specific policies (anti-corruption, protection of personal data, competition compliance), instructions and various communication.

The Compliance Program also applies outside CZG - Česká zbrojovka Group SE as CZG aims to comply with the relevant principles in all companies in its family that CZG brings together.

The rules stipulated in the Compliance Program are binding not only on employees or other persons belonging to the CZG family but we also demand that all entities cooperating in any manner with CZG promote the same moral values and that they manifest such will by accepting the rules of the program.

Thank you for acting in compliance with the above rules and principles and thereby contributing to promoting the law and moral conduct within the corporate culture.

Board of Directors CZG – Česká zbrojovka Group SE

DESCRIPTION OF THE COMPLIANCE PROGRAM

1. Purpose of the Program

The Compliance Program of Česká zbrojovka Group SE (hereinafter referred to as “CZG”) is intended to allow CZG to comply with applicable laws and internal regulations aimed at doing business in an ethical and legally sound manner. The below text identifies and describes the framework documents and instruments of the Compliance Program, summarises areas of compliance covered by the program, explains the compliance instrument system, including the approach to training and internal audit.

2. Scope

The Compliance Program is, to its full extent, binding on CZG, its individual employees and persons with a similar status, the Board of Directors and its members, the Supervisory Board and its members, the Audit Committee and its members, CZG officers authorised to act for or on behalf of CZG, and CZG officers in charge of management or audit tasks (hereinafter referred to as the “Relevant Persons”).

The Compliance Program is addressed to the Relevant Persons in CZG as well as other entities including but not limited to CZG group companies, i.e. companies directly or indirectly controlled by a CZG company, companies managed by a CZG company, which are hereby requested by CZG to implement the comprehensive Compliance Program.

3. Description of Framework Compliance Instruments

Strict compliance with the Compliance Program

CZG strictly complies with the rules and principles set forth in the Compliance Program. CZG promotes the principles of ethical behaviour and motivates the Relevant Persons to comply with them. Violations of the above rule are subject to CZG’s actions against the Relevant Persons.

Code of Ethics

The Code of Conduct clarifies the basic principles of conduct of the Relevant Persons in CZG and the CZG group companies.

Specific rules for employees in the individual areas of compliance

These manuals give employees and the Relevant Persons a practical guidance designed to promote the objectives of CZG and CZG group companies for compliance with the relevant legal and moral rules in the following areas of compliance: anti-corruption, competition, protection of personal data.

Compliance Department

The department staff includes a compliance officer nominated by the Board of Directors to be in charge of the application, supervision and improvement of the Compliance Program.

Monitoring of laws and best practices in areas regulated by the Compliance Program

CZG systematically monitors all changes in statutory obligations and compliance therewith. Measures are adopted and changes are implemented in the modified compliance rules in consideration of the monitoring results and in accordance with best practices.

Regular risk assessment

CZG regularly reviews the rules for the individual areas of compliance, reduces associated risks and assesses the effectiveness of the existing Compliance Program.

CZG will amend and elaborate on the existing rules and implement additional principles from time to time in consideration of the results of the measures taken.

Whistleblowing

Whistleblowing is a set of measures aimed at detecting unethical conduct by disclosing information to persons or entities (Compliance Department) that may examine and properly investigate the report and take action if necessary (“Compliance Line”).

Training and awareness

Awareness of the Relevant Persons of the principles and rules set for the individual areas of compliance is one of the fundamentals of the Compliance Program. For this purpose, CZG will train all employees and the Relevant Persons correspondingly in all the specific areas of compliance. The training is organised in accordance with the CZG risk profile and is adequate to the level of responsibility of the relevant employee.

4. Overview of Areas of Compliance

Anti-corruption

Anti-corruption laws criminalize corruption and improper influence aimed against someone who has been entrusted with acting on behalf of others. Violations may result in sizeable monetary penalties, imprisonment and, last but not least, the penalty of dissolution of the legal entity. The Anti-Corruption Policy provides guidance and restrictions in dealing with the public and private sectors in regard to hospitality, corporate events, gifts and charity.

Competition

Competition laws promote or are aimed at protecting the competition in the market by regulating behaviour that distorts competition. The Competition Compliance Policy provides guidance for dealing with competitors, suppliers, distributors and customers and for preventing abuse of market position.

Personal data protection

Data protection laws impose privacy protection procedures for the disclosure and processing of information concerning employees, customers and other individuals. The Privacy Policy provides guidance for major aspects of personal data protection, including data collection and processing, access to and retention of data as well as the quality, confidentiality and security of data.

WHISTLEBLOWING (COMPLIANCE LINE)

Being aware of its obligation to monitor and promote compliance with laws and moral and ethical principles, CZG has implemented a uniform system for reporting suspicions of unethical conduct which many be used by anyone (employee, customer, partner etc.) to report any such conduct.

Conduct considered by CZG to be unethical includes but is not limited to:

  • violations of laws and regulations and compliance principles;
  • fraudulent, improper and incorrect accounting books and reports, final statements, falsifying and influencing audit;
  • violations of the rules of competition;
  • acting in conflict of interest;
  • misuse of trade secrets;
  • conduct promoting or soliciting corruption, corruption itself;
  • embezzlement and theft of financial assets and/or property;
  • improper conduct in terms of occupational safety, fire protection, environmental protection;
  • falsifying contracts;
  • misuse of information in trade;
  • accepting working conditions which are in violation of the rules of ethical conduct (such as violations of human rights);
  • providing unethical and false information (in whistleblowing) with a view to cause harm to another person or company.

The CZG commits to protect, within its powers, persons, who reported unethical conduct in good faith, from any retaliation or any form of discrimination from the reported party.

In addition, CZG guarantees that no employee will be retaliated (dismissal, transfer to an inferior job position, bonus reductions etc.) for exercising ethical whistleblower activities.

FORM

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