Seznam Ethical Code

The company Seznam.cz, a.s., with its registered office at Radlická 3294/10, 150 00 Prague 5, ID: 26168685, registered in the Commercial Register maintained by the Municipal Court in Prague, Section B, Insert 6493 (hereinafter referred to as “Seznam.cz” or “publisher”), hereby issues the following code of ethics (hereinafter referred to as the “Code of Ethics”).

The Code of Ethics is a fundamental document describing the principles of ethical behavior of employees of Seznam.cz, a.s. (hereinafter referred to as the “employer”). Its aim is to set a unified understanding of the manifestations of shared values in everyday work practice. The Code of Ethics is a binding document for all employees and members of the employer’s bodies (hereinafter collectively referred to as “employees” for the purposes of this Code of Ethics). One of the basic principles on which the code is based is that employees are aware that their actions may expose the employer and themselves to criminal, administrative, or civil penalties, and therefore act to prevent criminal activity or other violations of legal and internal regulations. The employer therefore does not tolerate any violation of the Code of Ethics and may also consider it a serious breach of work duties. The Code of Ethics expresses our commitment to ethical conduct towards partners, users, and colleagues.

General Principles

The employer undertakes to comply with legal regulations guaranteeing employees such working conditions and environment that allow for safe work performance, including preventing work-related stress. For this reason, it offers employees access to information about significant changes in the structure, functioning, and activities of the employer, primarily through the intranet Neznám or other internal communication channels, such as email messages. Similarly, the employer approaches the prevention of the risk of violence and harassment in the workplace. Regular status meetings between the employee and their superior serve to clarify the roles of individual employees. Given the informal culture at Seznam.cz, the employee also has the opportunity to contact their superior, the relevant director, the HR department, or the Ethics Committee at any time (not only in case of uncertainties or questions).
Employees comply with all legal regulations and also internal regulations and instructions of the employer in their work. Employees follow relevant legal regulations needed for their work performance.
Employees perform their work to the best of their knowledge and abilities, with the highest level of professionalism, decency, and willingness to help third parties. A third party is understood as any natural or legal person different from the employer and the employee, including a business partner or public administration bodies (hereinafter referred to as “third party”). Employees always act in a way that does not mislead third parties, providing only truthful and accurate information. They are aware that their behavior and demeanor represent the employer. They act transparently and support good morals. They take care of their appearance and clothing to match their work assignment.
Employees contribute to creating a good reputation for the employer, its products, and services, even in their non-work activities that they present publicly (e.g., on social networks). Together, they strive to achieve ever better results for the employer.
Employees protect the legitimate interests and good name and reputation of the employer, colleagues, and third parties. They actively avoid conflicts of personal or family interests with the interests of the employer. In the event of such a conflict of interest, they immediately inform the employer. Employees are obliged to take measures to eliminate the impact of the conflict of interest proposed by the employer. Employees may engage in gainful activities identical to the employer’s business only with its prior written consent (approved by the relevant director, administered by the HR department) in accordance with § 304 of the Labor Code. In the internal system, they regularly confirm that they do not engage in such activities. For any gainful activity, even one that does not match the employer’s business and does not require approval, they do not use the resources and work tools entrusted to them by the employer.
Employees make every effort to ensure the economical use of the employer’s assets and entrusted values. In fulfilling work duties, they proceed in a way that does not incur unnecessary costs for the employer. Employees are not authorized to unlawfully appropriate financial resources, sources, or assets of the employer, other employees, or third parties for their own needs or the needs of another person.
Employees respect the property rights of third parties. Employees fulfill their work duties in a way that prevents damage to the health and property of the employer or third parties or the environment. If there is an immediate danger of damage, employees try to avert the damage. If this is not possible, they inform people who can avert or mitigate the damage. Employees always inform the employer about the danger of damage.
If an employee discovers damage that has occurred to the employer, they report the occurrence of the damage without undue delay.
Employees protect the intellectual property rights of the employer and respect and protect the intellectual property of third parties.
Employees ensure safety protection when using IT systems and processing data.
Employees who come into contact with personal data of third parties in the performance of their work duties are obliged to handle personal data in accordance with legal regulations governing the protection of personal data, especially in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), Act No. 110/2019 Coll., on the processing of personal data, as amended, and Act No. 111/2019 Coll., amending certain laws with the adoption of the Act on the processing of personal data, as amended. Employees are obliged to protect personal data and handle it as confidential information and are not authorized to pass personal data to third parties. Any violation of handling personal data or its leakage must be reported by employees to the employer without undue delay.
Employees respect and strictly adhere to the confidentiality of transported messages, i.e., they do not access the content of users’ email accounts of the employer (unless required by their job and done in accordance with the employer’s internal procedures), nor do they access the content of written or email correspondence of other employees. If they become aware of this content, they maintain confidentiality about it.
Employees do not misuse their position, the employer’s property or equipment, their working time, or information they learn in the course of their work for their private interests or the interests of third parties, even after the termination of their employment.
Employees maintain impartiality and equal access to all natural and legal persons.
If an employee is authorized to legally act on behalf of the employer in defined matters, such as concluding contracts or placing orders, they are obliged to adhere to the limits of such authorization.
When negotiating contractual relationships with the employer’s partners, responsible employees are obliged to consider the risks of entering into a contractual relationship, including verifying the contractual partner in available public registers (e.g., insolvency register or unreliable taxpayer register). The responsible employee informs the employer of any risks of entering into a contractual relationship.
The employer complies with all tax legal regulations, and the responsible employees are obliged to make every effort to ensure that all obligations of the employer towards the tax administrator are fulfilled properly and on time. Employees are obliged to report to the employer any payments that cannot be identified or associated with specific performance.
The employer does not allow any forms of unfair competition, and employees make every effort to prevent unfair competition. Unfair competition is understood as conduct contrary to good morals of economic competition, which is capable of causing harm to other entities, including business partners, competitors, and/or users of the employer.
If an employee is asked or pressured to act contrary to legal regulations, internal regulations, or instructions from a superior or another employee, they are obliged to refuse such conduct and report it to the employer. Supervisors maintain equal access among their subordinates, emphasizing results and quality of work in their selection, evaluation, and development. They enable further development to improve work efficiency, support the use of acquired skills and knowledge in practice, and are responsible for the full integration of their subordinates into work teams. They are role models not only in applying the Code of Ethics.
If an employee, out of their own decision in the interest of the employer or within its activities, commits a criminal offense, it is their violation of legal regulations, in which the employer does not participate in any way.
If there are uncertainties on the part of the employee regarding the employer’s decisions, instructions, or interpretation of legal or internal regulations, the employee is obliged to request all necessary information or opinions to minimize the risk of their violation by the employee.
Colleagues maintain correct and decent relationships among themselves. They support mutual cooperation and contribute to creating an atmosphere of trust. They resolve any disputes calmly and factually.

Anti-Corruption Measures

The employer applies a zero-tolerance approach to bribery and corruption, and therefore sets rules in this part of the Code of Ethics for providing gifts to third parties and accepting gifts from third parties to create a system for combating bribery.
Definitions used in Article II of the Code of Ethics.
- For the purposes of this directive, gifts are considered any tangible items, provided hospitality (invitation to lunch or a social event), private trips, monetary contributions or their equivalents, and other benefits (hereinafter referred to as “gift” or “gifts”).
- A bribe is understood as an offered, promised, or provided gift aimed at obtaining any benefit for oneself or another (e.g., business, contractual, or personal) (hereinafter referred to as “bribe”). Offering, promising, or providing a bribe or demanding, agreeing to receive, or accepting a bribe are criminal offenses for which both natural and legal persons can be criminally liable. Bribery is also an act constituting unfair competition.
Rules for providing and accepting gifts.
- An employee may provide or accept only a gift that is not a bribe.
- Providing or accepting gifts complies with legal regulations and customs (customary gifts are allowed, such as birthday and other anniversary gifts, Christmas or other significant event gifts, invitations to a partner’s party, to an educational event related to work performance, etc.).
- Gifts are reasonable in terms of value and frequency.
- Gifts are provided and accepted openly, in the name of the employer, not in one’s own name.
- It is prohibited to provide or accept gifts if they involve cash. Gift vouchers for goods or services can be provided or accepted only if such vouchers do not allow exchange for cash.
- Business trips paid for by a third party can be extended by the employee for private reasons exclusively at the employee’s expense and in their free time. Participation of family members in a business trip paid for by a third party is not allowed.
- Accepting any gifts during the selection process (even informal) is prohibited.
Recording and approval.
- For each department of the employer, an employee appointed by the relevant director keeps a monthly record, in which employees of the respective department are obliged to report:
  - A gift provided or received by an employee valued over 500 CZK, with the decisive factor being the usual price of the gift (i.e., the price that would be achieved in the sale of the same or similar gift) at the time of gifting, in the case of hospitality, the limit is per person. Special records according to the Code of Ethics do not include business lunches, dinners, or similarly provided/received hospitality. Provided hospitality is recorded as part of the representation expenses of each department paid from the department’s budget.
  - Any gift refused by an employee regardless of its value, including the reason for refusal.
  - Gifts falling into the employee’s free time regardless of their value (weekend stay, etc.).
- The relevant department director must approve for their department’s employees:
  - Providing or accepting gifts valued over 3,000 CZK.
  - Business and other trips paid for by a third party regardless of their value.
  - Gifts provided to or received from an official person regardless of their value.
- The employee is obliged to request the director’s approval in advance; if this is not possible, the employee requests it subsequently. If the relevant director does not give consent to the employee for providing or accepting a gift, the employee is obliged not to proceed with the gifting, refuse the gift, or return it.
- If the giver/recipient is the department director, approval according to this point belongs to the chairman or any member of the employer’s board of directors.
- Records in the register include the name of the giver and recipient, the designation of the gift item, the value of the gift (if the exact value is unknown, the employee provides an estimated value based on publicly available information), and the date of its receipt/provision/refusal. If it is a gift whose provision or acceptance is subject to approval, the records must also include the decision of the approver.
- Any exceptions to the rules stated in this section are subject to the consent of the employer’s board of directors.
- The person authorized to approve the provision or acceptance of a gift may request further information about such a gift from the employee, and the employee is obliged to provide this information.

Crime Prevention

The employer does not tolerate any form of criminal activity by employees related to their work activities or performance of duties. The effort to prevent criminal liability of the employer is one of the employer’s goals. Employees have the obligation to act honestly and make every effort to prevent criminal activity by natural persons that could be attributed to the employer under § 8 of Act No. 418/2011 Coll., on criminal liability of legal entities and proceedings against them, as amended.
In case of doubts about a superior’s instruction or decision, the employee is entitled to assess the compliance of such instruction or decision with legal or internal regulations or the Code of Ethics.
If there is a suspicion that an employee could commit a criminal offense through their actions, the employee is obliged to report this suspicion to the employer and request its instructions. If the employee discovers illegal conduct or a continuing illegal state within the employer’s activities, they will make an effort, considering the circumstances of the case, that can be reasonably demanded of them to prevent the illegal conduct or state and avert its harmful consequences. At the same time, the employee informs the employer of this fact.

Resolving Situations in Conflict with the Code of Ethics

To resolve situations where there is a threat or already a conflict with the Code of Ethics, an Ethics Committee appointed by the employer’s statutory body is established.
If an employee learns of possible more serious illegal conduct, they can report it also through the Internal Reporting System, which is established by the employer in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers, as amended (hereinafter referred to as the “Whistleblower Protection Act”).

The Internal Reporting System consists of establishing secure channels for reporting possible illegal conduct, ensuring the protection of the whistleblower’s identity.
Through the Internal Reporting System, it is possible to report possible illegal conduct that:
- Has the characteristics of a criminal offense.
- Has the characteristics of an offense for which the law sets a fine rate, the upper limit of which is at least 100,000 CZK.
- Violates the Whistleblower Protection Act.
- Violates another legal regulation or European Union regulation in the area of financial services, mandatory audit and other verification services, financial products and financial markets, corporate income tax, prevention of money laundering and terrorist financing, consumer protection, compliance with product requirements including their safety, transport safety, transportation and operation on roads, environmental protection, food and feed safety and animal health, radiation protection and nuclear safety, competition, public auctions and public procurement, internal order and security, life and health protection, personal data protection, privacy and security of electronic communications networks and information systems, protection of the financial interests of the European Union, or functioning of the internal market including competition protection and state aid under European Union law.
The method of submitting reports and further details regarding the Internal Reporting System and whistleblower protection are governed by the employer’s internal regulation “Whistleblower Protection”.

In cases where the Code of Ethics stipulates that an employee is obliged to report certain information to the employer, the employee addresses this matter at their discretion to their superior, their director, or the Ethics Committee. In the case of more serious illegal conduct as per Article IV, paragraph 2 of this Code of Ethics, the employee may also submit a report through the Internal Reporting System. If the subject of the employee’s report is a suspicion of a violation of the rules stated in Article II of the Code of Ethics or a suspicion of any illegal conduct, the superior or director to whom the report was made is obliged to inform the Ethics Committee or submit a report through the Internal Reporting System.

Ethics Committee

A member of the Ethics Committee cannot be a member of the employer’s statutory or supervisory body.
The Ethics Committee addresses reported suspicions of illegal conduct within the employer’s activities, complaints related to the Code of Ethics, evaluates compliance with the Code of Ethics across the employer’s company, proposes further steps to the employer’s board of directors in case of proven illegal conduct or conduct contrary to the Code of Ethics, unless this procedure is determined by other legal or internal regulations of the employer. The Ethics Committee proposes further measures to the employer’s board of directors aimed at promoting and complying with the Code of Ethics. The Ethics Committee is responsible for deciding whether specific conduct violated the Code of Ethics. Other conclusions and resolutions of the Ethics Committee have a recommendatory character for the employer’s board of directors, which subsequently decides on their implementation.
The Ethics Committee always proceeds in accordance with the Ethics Committee’s rules of procedure.
An employee can use the following means to report to the Ethics Committee according to this Code of Ethics:
- Through a mailbox located at the employer’s headquarters and selected branches. The mailboxes will be placed out of reach of the employer’s monitoring system.
- Through a postal service provider, with the shipment addressed to the Ethics Committee with the employer’s headquarters address.
- Through an email message sent to the Ethics Committee’s email address etickakomise@firma.seznam.cz.
A report intended for the Ethics Committee should include, in particular, the identification of persons suspected of illegal conduct and all persons involved in this conduct, a description of the illegal conduct, any evidence of illegal conduct, and other specific findings supporting the suspicion of illegal conduct.
An employee may choose the option of anonymous reporting at their discretion.
All submissions addressed to the Ethics Committee will be treated as strictly confidential, including the possible identity of the whistleblower. The employer will not penalize employees who, in good faith, reported suspicions of conduct contrary to the Code of Ethics, illegal conduct, and/or corrupt conduct. If an employee makes a non-anonymous report to the Ethics Committee, they will subsequently be informed of the Ethics Committee’s decisions and any measures taken by the employer’s board of directors regarding the report they made.
In the case of justified complaints, the employer undertakes to ensure appropriate remediation and take appropriate measures to prevent similar situations that were the subject of the complaint from recurring in the future.

Final Provisions

The responsibility for implementing the Code of Ethics lies with the employer’s board of directors, which ensures that all employees are properly and demonstrably acquainted with the Code of Ethics.