Information for whistleblowers

Tack Room Capital s.r.o., Company ID: 21743762, with its registered office at Opletalova 1015/55, Nové Město, 110 00 Prague 1 (the “Company” or “we”), has set up an internal whistleblowing system.

Under Section 21(6)(b) of Act No. 253/2008 Coll., on certain measures against the legalisation of proceeds of crime and the financing of terrorism (“AML”), every obliged entity must set up an internal whistleblowing system within the meaning of Act No. 171/2023 Coll., on the protection of whistleblowers (the “Whistleblower Protection Act”). As part of this system, every worker (including people who work for the Company other than under a standard employment relationship) may report the conduct described below anonymously.

So whether you are our employee, intern, supplier, executive, authorised signatory or anyone else working for our Company in any capacity, you can use our internal whistleblowing system.

Overview of the internal whistleblowing system

What conduct can be reported?

The Whistleblower Protection Act allows reports on several levels. If you witness conduct that:

• has the hallmarks of a criminal offence;

• has the hallmarks of an administrative offence for which the law sets a fine with an upper limit of at least CZK 100,000;

• breaches the Whistleblower Protection Act;

• breaches Czech or European Union law in the area of financial services, statutory audit and other assurance services, financial products and financial markets;

• breaches Czech or European Union law in the area of corporate income tax, prevention of money laundering and terrorist financing, consumer protection, transport and road safety, environmental protection, food and feed safety, animal health and welfare, radiation protection and nuclear safety, competition, public auctions and public procurement, protection of internal order and security, life and health;

• breaches the law on the protection of personal data, privacy and the security of electronic communications networks and information systems, the protection of the European Union’s financial interests, or the functioning of the internal market, including the protection of competition and state aid under European Union law;

You do not have to witness such conduct being completed. It is enough to suspect that such conduct is imminent and to have reasonable grounds to believe that its consequences could occur in the future.

It is important that you have good reason to believe that the facts you report or disclose are genuine and true. A report should also be based on credible facts.

The Whistleblower Protection Act does have its limits. If you were to report matters concerning the security of the Czech Republic (for example, a contract for the army), we could not assess the report under the Whistleblower Protection Act, because such information is excluded from reporting. The specific list of excluded areas is in Section 3(3) of the Whistleblower Protection Act (mainly security matters, intelligence services and similar). If you file a report in these areas, you are not protected under the Whistleblower Protection Act and you may also commit an administrative or even a criminal offence.

You can also make any report anonymously, and we guarantee that we will deal with it in the same way as a report that is not anonymous.

Who handles reports?

Your report will be received by our designated person:

• Mgr. Jiří Hradský, tel. +420 739 914 552, e-mail: jiri.h@sedlakovalegal.com

The designated person is bound by confidentiality and will protect your identity and the information you provide. The designated person may investigate a report together with others or alone. If you make an anonymous report, the designated person will not try to find out who you are.

Please note: if we find that a report is knowingly false, you are not protected, you may be fined under the Whistleblower Protection Act, and the Company may take further measures.

How to make a report

You can make a report:

• by e-mail to jiri.h@sedlakovalegal.com;

• orally, by phone on +420 739 914 552;

• orally in person, at the Company’s registered office or another place agreed with the designated person (you can arrange this using the designated person’s contact details above). You will be able to make the report within a reasonable time after your request, and no later than 14 days.

If you make a report in any other way than through the channels above (for example, by e-mail to another colleague at the Company), it will not be treated as a report within the meaning of the Whistleblower Protection Act. The Company may then deal with it in another way, and you will not be protected under the Whistleblower Protection Act.

External reporting

Besides the internal whistleblowing system, the Whistleblower Protection Act also allows other ways of reporting. These external channels are:

• a report through the Ministry of Justice whistleblowing system, available at https://oznamovatel.justice.cz/;

• a report by public disclosure, for example to the media (but only in the cases listed in Section 7(1)(c) of the Whistleblower Protection Act).

Because we are subject to AML rules, specific rules also apply to where external reports can be made. If a report concerns a breach of AML rules by any of our workers, management or similar, you cannot make an external report through the Ministry of Justice system or disclose it publicly. In that case, the report must be made to the Financial Analytical Office. Contact details for making a report are at https://fau.gov.cz/kontakty.