Whistleblowing Policy
Whistleblowing Policy
Internal whistleblowing mechanism | |
On the basis of Act No. 171/2023 Coll, on the protection of whistleblowers, dated 2 June 2023 BlockWave Innovations s.r.o. has developed mechanisms enabling employees and other persons to report on any suspicions of possible harmful conduct within the Company and for this the Company has developed and implemented an internal whistleblowing mechanism based on Whistleblowing Mechanism Rules (WMR), which is intended for employees and other natural persons who, in connection with their work or other similar activities pursuant to Section 2(3) of the Act, become aware of an unlawful act that has the characteristics of: | |
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The report shall contain: | |
1) information enabling the identity of the whistleblower to be established. Anonymous notifications shall not be processed with some exceptions detailed in the WMR; 2) description regarding possible existing or imminent unlawful conduct, violations of relevant legal regulations or obligations arising therefrom. Company excludes the receipt of Reports from persons who do not perform work or other similar activities for the Company pursuant to the provisions of Section 2(3)(a), (b) and (h) of the Act. | |
Notification to BlockWave Innovations s.r.o. can be made: 1. in paper form by sending it to the address of the registered office of Blockwave Innovations s.r.o. marked "Do not open - WHISTLEBLOWER", 2. electronically to the established mailbox for electronic mail at: [email protected], 3. orally before a competent person who will draw up a report on such notification, 4. orally by means of a telephone conversation with a competent person with an audio recording, provided that the whistleblower consents to the recording. | |
For the purpose of Whistleblower reports review and investigation the Company has appointed a Whistleblower Officer who is in charge to receive the reports, investigate revealed facts, ensure Whistleblower protection as well as to enforce all the provisions of the WMR. The Whistleblower Officer according to Act No. 171/2023 Coll. is MR/MS. Oleg ZAJAC. Tel. of the Whistleblower Officer +420 775544612 The Whistleblower Officer can be reached by telephone between 10.00 and 15.00 CET Monday to Friday. | |
Purpose of the AML Policy
BlockWave Innovations s.r.o. has internal guidelines to prevent the use of its business for money laundering and terrorist financing and internal guidelines for implementation of international sanctions.
To ensure full protection of our services, we have developed and enforced an internal AML Policy to cover all necessary measures. We are wholeheartedly dedicated to adhering to the AML requirements set forth by the Czech Republic's laws, as well as those outlined by the European Union and international guidelines.
Definition of AML Policy
An AML Policy comprises procedures and measures were developed to prevent money laundering, illegal activities, terrorist funding, or other criminal actions. The AML Policy includes the implementation of KYC measures. Procedures and methods intended to stop money laundering, illicit activity, terrorist financing, and other criminal acts are included in an AML policy. KYC measures are implemented as part of the AML Policy.
In the event of any suspicious conduct or strange consumer behavior, we take all required steps and report it to the appropriate unit. Our tem may ask for more details on the activities of the customer's account as part of this procedure, such as the Source of Funds/Source of Wealth (SOF/SOW) or any other document we deem necessary for the benefit of our clients.
The data collected is handled with care and all documents relating to customers' personal data are kept confidential and comply with personal data protection regulations.
BlockWave Innovations s.r.o. AML Policy includes:
– KYC involves identifying and verifying the customer before starting a financial relationship
– Given the risk-based strategy, we assess the degree of risk and use due investigation, including increased due diligence for clients – who exposes us to a higher risk
– Procedures for reporting suspicious activities internally and externally
– Procedure for identifying the subject of Sanctions and a transaction violating Sanctions
The above approach obliges us to refuse employment, block the account and completely terminate the relationship with the client in the event of suspicious activity, non-cooperation and manipulation of documents provided as part of the client due diligence process.
API documentation
API documentation