Overview of legal regulations and anti-corruption program

The Transport Research Center publishes all documents related to the anti-corruption program and obligations under applicable legislation. On this page, you will find an overview of the regulations, internal measures, and legal standards that govern the institution.

Overview of the most important legal regulations according to which CDV acts and makes decisions

• Act No. 106/1999 Coll., on free access to information, as amended

• Act No. 320/2001 Coll., on financial control in public administration and on amendments to certain acts (Act on Financial Control), as amended

• Act No. 130/2002 Coll., on support for research, experimental development, and innovation from public funds and on amendments to certain related acts (Act on Support for Research and Development), as amended

• Act No. 341/2005 Coll., on public research institutions, as amended

• Act No. 89/2012 Coll., Civil Code, as amended

• Act No. 134/2016 Coll., on public procurement, as amended

• Act No. 110/2019 Coll., on the processing of personal data

Anti-Corruption Program

Introduction to the Anti-Corruption Programme

The Transport Research Centre, v. v. i. (hereinafter referred to as CDV) issues this directive as a binding internal regulation defining a uniform framework for managing corruption risks and ensuring the integrity of all the organisation’s processes; the directive sets standards for professional and transparent conduct, defines the obligations of employees and persons acting on behalf of CDV, regulates the rules for the handling of public funds, the prevention of conflicts of interest, the acceptance of gifts and the provision of hospitality, sets out requirements for responsible procurement and cooperation with external entities, and describes mechanisms for reporting suspected unlawful or unethical conduct, including the protection of whistleblowers; the guidelines represent a key internal management and control tool, the aim of which is to maintain high standards of ethics, transparency and responsible conduct in CDV’s activities.

What you can expect from the programme

• Clear rules for conduct in the areas of public procurement, gifts, conflicts of interest and the handling of assets.

• Practical procedures for identifying risks and addressing them in day-to-day work.

• Secure channels for reporting suspicious, unethical or unlawful conduct without fear of retaliation.

• Support and training so that everyone knows how to act correctly and where to turn for advice.

Why is this important

• It helps us maintain the institution’s good reputation and make effective use of research funds.

• It protects you and your colleagues from unpleasant situations and legal risks.

• It fosters an environment where professionalism and mutual trust are valued.

What we expect from you

• Adherence to the rules and reporting of situations that you consider problematic.

• Open communication and a willingness to participate in training.

• Respect for internal procedures and the decisions of those in charge.

This document is based on recommendations from the Ministry of Transport and has been adapted to the specific requirements of CDV. In the following sections, you will find specific procedures, contact details for the relevant persons, and sample forms for reporting and preventing risks. If you require assistance or clarification, please contact the Internal Audit Department or the designated anti-corruption officer.

Definition of corruption and what we consider to be corruption

Corruption is the abuse of position, authority or function for personal gain, associated with a breach of the principle of impartiality in decision-making.

The following, in particular, may be considered corrupt conduct:

• Accepting or offering bribes (money, gifts, benefits in exchange for favourable treatment).

• Unjustified favouritism towards suppliers or colleagues (nepotism, cronyism).

• Manipulation of public contracts, grants or accounts for the purpose of obtaining an unjustified advantage.

• Extortion, intimidation or other forms of coercion related to the performance of one’s duties.

• Misuse of internal information or assets for personal gain (e.g. misuse of data, unauthorised transfers of assets).

For clarity, we can define the following basic forms of corrupt or corruption-related conduct:

• Petty administrative corruption is generally unsystematic and lacks the sophistication of more serious forms of corrupt conduct. This includes, for example, offering small gifts in exchange for the preferential handling of requests and the like.

• Non-transparent lobbying involves influencing public officials outside the established legal framework of clear and transparent rules, often to benefit the hidden private interests of third parties.

• A conflict of interest arises in a situation where a person empowered to decide on a matter also has a personal interest in that matter being decided in a specific way (i.e. their impartiality is called into question). The mere existence of a conflict of interest does not in itself constitute corruption, but it creates conditions in which corrupt conduct may occur.

• Nepotism involves the appointment of relatives or otherwise connected individuals to selected positions at the expense of more qualified candidates.

• Clientelism consists of unfair ‘backroom’ cooperation by an informal group that systematically favours its members or, conversely, deliberately disadvantages those who are not members of the clientelist group.

• State capture occurs when key positions within the state apparatus (government, public authorities, courts, and the like) are systematically taken over by individuals serving the private interests of a single person or group of people rather than the interests of the state’s citizens. This is the most serious form of corrupt conduct, threatening the very foundations of the state’s constitutional system.

Regardless of its specific form, corrupt conduct is, by its very nature, at odds with moral values such as integrity, impartiality and honesty, and as such is therefore always unethical. However, corruption often constitutes not only a breach of ethical standards, but also a breach of the law. Although Act No. 40/2009 Coll., the Criminal Code, as amended (hereinafter the “Criminal Code”), does not recognise the term “corruption” as such, corrupt conduct may constitute the elements of several different criminal offences. The most common are as follows:

• Bribery (sections 331 to 334 of the Criminal Code).

• Abuse of authority by a public official (Section 329 of the Criminal Code).

• Misuse of information in business dealings (Section 255 of the Criminal Code).

• Abuse of position in business dealings (Section 255a of the Criminal Code).

• Securing an advantage in the award of a public contract, in a public tender or in a public auction (Section 256 of the Criminal Code).

• Manipulation in the award of public contracts and in public tenders (Section 257 of the Criminal Code).

• Conspiracy in public auctions (Section 258 of the Criminal Code).

Objectives of the anti-corruption programme

The primary objective of the internal anti-corruption programme of the Transport Research Centre, v. v. i. (CDV) is to reduce the likelihood of corruption and to assist in the detection of any corrupt conduct within the institution. The programme sets out specific tasks divided into four main areas, tailored to the specific nature of a research organisation.

Internal Anti-Corruption Programme

1 Creating and strengthening an anti-corruption climate

Objective: To reduce the motivation of employees to engage in unethical or unlawful conduct and to strengthen a culture of accountability.

Tasks: Introduce regular training on ethics and anti-corruption principles; communicate clear values and management expectations; encourage open communication and the sharing of concerns without fear of reprisal.

Metrics: Percentage of employees trained; results of anonymous integrity perception surveys.

1.1 Regular inclusion of topics in departmental and divisional management meetings

Objective: Department/division heads regularly include topics related to the Code of Ethics and the fight against corruption (prevention, methods, practical examples) in meetings and management discussions. In addition to meetings, they raise awareness of ethical values and anti-corruption principles through other channels (intranet, internal newsletters, short workshops).

Responsible: heads of departments/divisions

Deadline: ongoing and continuous

1.2 Training and practical examples

1.2.1 Department/division heads familiarise their subordinates with clear examples of ethical and unethical conduct and with specific corruption risks relevant to the department’s activities. They provide expert answers to employees’ queries and, where necessary, arrange consultation with the internal audit department or the designated anti-corruption officer.

Responsible: heads of departments/divisions

Deadline: ongoing and continuous

1.3 Induction and targeted training in ethics and anti-corruption

1.3.1 Ensure, as part of induction training for new employees, an introductory course focused on compliance with the Code of Ethics and the basic principles of anti-corruption (scope, responsibilities, reporting channels).

Responsible: Head of the Human Resources Department in cooperation with the designated anti-corruption officer

Deadline: ongoing and continuous

1.3.2 Set training objectives related to the fight against corruption in the individual training plans of employees assigned to organisational units at higher risk of corruption, in accordance with the internal catalogue of corruption risks. Review and update these objectives at least once a year.

Responsible: Heads of areas and departments at higher risk of corruption, in cooperation with the HR department

Deadline: once a year (review) / on an ongoing and continuous basis (implementation)

1.3.3 Set out specific anti-corruption training objectives in the individual training plans of directly subordinate staff members performing activities for which the Ministry of Transport’s Catalogue of Corruption Risks has identified elimination measures consisting of training for the responsible staff members.

Responsible: Heads of areas and departments in which such activities have been identified

Deadline: at least once every two years

1.3.4 Based on individual training plans, incorporate training activities related to the fight against corruption into the comprehensive training plan and ensure their implementation.

Responsible: Head of the Human Resources Department

Deadline: once a year (scheduling and ensuring delivery)

2 Transparency

2.1 Transparent communication of findings and resolutions

2.1.1 Managers shall, to the extent that this does not jeopardise ongoing investigations or the protection of personal data, inform their subordinates about recorded incidents, how they were resolved, and the consequences of unethical or unlawful conduct. The aim is to share experiences and strengthen prevention.

Responsible: Heads of divisions and departments in cooperation with the Integrated Management System Department

Deadline: ongoing and continuous

2.2 Monitoring compliance with rules, investigating suspicions and disciplinary measures

2.2.1 Managers regularly monitor compliance with the Code of Ethics and anti-corruption rules among their subordinates and address any identified breaches in a timely manner in accordance with internal procedures. They ensure a timely, thorough and impartial investigation of suspected corrupt conduct; if a breach of the rules or the law is proven, they take appropriate disciplinary and other measures in accordance with internal regulations and legislation. During investigations, the protection of whistleblowers and the rights of those concerned is ensured; where necessary, action is taken in cooperation with the Integrated Management System Department, the Legal Department or external authorities.

Responsible: Heads of divisions and departments in cooperation with the Integrated Management System Department and the Legal Department

Deadline: ongoing and continuous

2.3 Promoting open communication and protecting whistleblowers

2.3.1 Managers promote open communication, encourage employees to report suspicions and ensure that secure and confidential reporting channels are available. They ensure that whistleblowers are not subjected to retaliation and that protective measures are put in place.

Responsible: Heads of divisions and departments in cooperation with the designated anti-corruption officer

Deadline: ongoing and continuous

2.4 . Increasing transparency

2.4.1 Improve the transparency of decision-making processes and facilitate the detection of irregularities.

Tasks: Publish procurement rules; document key decisions and selection criteria; maintain records of gifts and conflicts of interest.

Metrics: Availability and completeness of documentation; number of published and updated procedures.

For the purpose of publishing information on public funds (amendment for CDV)

2.4.2 Publish, check the validity and, where necessary, update information on the approved budget and final accounts of the chapter, or on the budget and final accounts of the CDV, on the CDV website.

Responsible: Director of the Finance and Administration Department (in cooperation with the web administrator/IT department for technical aspects)

Deadline: once a year

2.4.3 Publish, check the validity of, and, where necessary, update information on offers for the lease and sale of surplus assets managed by the CDV on the CDV website.

Responsible: Head of Asset Management and Operations (in cooperation with the web administrator/IT department for technical aspects)

Deadline: on an ongoing and continuous basis

2.4.4 Publish, check the validity of, and, where necessary, update information on completed public contracts, including small-scale contracts, for a period of at least two years via the contracting authority’s profile or the relevant section of the website.

Responsible: Head of the Legal Department (in cooperation with the web administrator/IT department for technical aspects)

Deadline: on an ongoing and permanent basis

2.4.5 Publish concluded contracts in a machine-readable format in accordance with the Contracts Register Act via the Contracts Register.

Responsible: Head of the Legal Department (in cooperation with the web administrator/IT department for technical aspects)

Deadline: ongoing and permanent

2.5 Publication of the organisational structure and contact details

2.5.1 Publish, check the validity of, and, where necessary, update information on the CDV’s organisational structure on the CDV website.

Responsible: Head of the HR Department (in cooperation with the web administrator/IT department for technical aspects)

Deadline: ongoing and continuous

2.5.2 In accordance with internal regulations, publish, check for up-to-date status and, where necessary, update the contact details of CDV management on the CDV website

Responsible: Head of the HR Department (in cooperation with the web administrator/IT department for technical aspects)

Deadline: ongoing and continuous

3 Corruption Risk Management

Objective: To establish effective preventive and control mechanisms to minimise the risk of corrupt conduct.

Tasks: Carry out regular risk mapping and assessment; introduce control procedures for key processes (public procurement, grants, assets); clearly define responsibilities and approval authorities.

Metrics: Number of identified and mitigated (residual) risks; results of internal audits; recommendations implemented.

Purpose: To systematically identify, assess and manage corruption risks within CDV and regularly verify the effectiveness of the measures taken.

3.1 Identification and updating of the risk catalogue (register)

3.1.1 Identify and assess corruption risks and establish measures to eliminate them.

Responsible: Division and department directors

Deadline: once a year

3.1.2 Update the CDV’s internal Catalogue of Corruption Risks (or the departmental catalogue to the extent that it relates to the CDV) based on the identification and assessment carried out.

Responsible: CDV Director in cooperation with division and department directors and the person responsible for anti-corruption matters

Deadline: once a year

3.2 Feedback mechanism and ongoing monitoring

3.2.1 Introduce, maintain and effectively utilise a feedback mechanism consisting of regular qualitative assessments, which will enable the verification of (a) the degree of implementation, the manner of fulfilment and the effectiveness of measures to eliminate key corruption risks or risks with an impact level of “very significant” or “critical”, and (b) developments in these areas.

Responsible: Directors of divisions and departments in which key risks have been identified

Deadline: ongoing and continuous

3.2.2 The CDV Director, in collaboration with the directors of divisions and departments, continuously monitors the level of implementation, the manner of execution and the effectiveness of measures to eliminate key corruption risks, or corruption risks with an impact level of ‘very significant’ or ‘critical’.

Responsible: The CDV Director and the directors of divisions and departments / heads of areas and sections (where key corruption risks with an impact level of “very significant” or “critical” have been identified in their organisational units).

Frequency: twice a year

3.3 Documentation, evaluation and review

3.3.1 Evaluate and record the degree of implementation, the manner of fulfilment and the effectiveness of measures to eliminate key corruption risks using corruption risk cards (risk cards).

Responsible: Directors of divisions and departments in which key risks have been identified

Deadline: at least once a year

3.3.1 Review the evaluation and recording process (including the content and updating of corruption risk cards) and verify the accuracy and completeness of the records.

Responsible: CDV Director in cooperation with division and department directors and the Integrated Management System Department/designated anti-corruption officer

Deadline: once a year

3.4 Reporting of possible unlawful conduct and protection of whistleblowers

3.4.1 Encourage employees to report suspicions and ensure their protection against retaliation.

Tasks: Ensure secure and confidential reporting channels; establish procedures for investigating reports; introduce protective measures against retaliation and sanctions for unjustified reprisals against whistleblowers.

Metrics: Number of reports received; processing time; feedback from whistleblowers on the security of the process.

3.5 Ongoing Evaluation and Improvement

3.5.1 Regularly monitor the fulfilment of the programme’s objectives and adjust measures in line with current risks and experience.

Tasks: Conduct an annual review of the programme; evaluate the effectiveness of measures based on audits, investigations and feedback; update the programme in line with legislation and best practice.

Metrics: Reviews and updates carried out; improvements implemented; improvement in indicators compared to previous periods.

4 Whistleblower protection

4.1 CDV’s internal reporting system A safe space for fair cooperation

The Transport Research Centre, v. v. i. (CDV), prides itself on openness, fairness and compliance with the law. Therefore, in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers, we have established an internal reporting system.

This system enables anyone who works for, collaborates with, or has previously carried out activities for CDV (for example, as an employee, job applicant, trainee, intern, volunteer, contractor or member of a legal entity’s governing body) to safely report potential unlawful conduct. Our aim is for everyone to feel protected and confident that their report will be investigated impartially and thoroughly.

4.2 Who can make a report

Any individual who, in connection with their work or collaboration with CDV, has become aware of possible unlawful conduct may submit a report. This includes, for example:

• Zaměstnanci/kyně CDV,

• uchazeči/ky o zaměstnání,

• praktikanti/ky, stážisté/ky a dobrovolníci/ice,

• osoby samostatně výdělečně činné (OSVČ) poskytující služby CDV,

• zaměstnanci/kyně dodavatelů a subdodavatelů,

• členové/ky orgánů právnických osob.

4.3 What can be reported

• criminal offences,

• administrative offences with a maximum fine of at least CZK 100,000,

• breach of the Whistleblower Protection Act,

• breaches of other legislation or EU regulations in areas such as:

  • protection of life and health,

  • security and public order,

  • data protection,

  • competition and public procurement,

  • environmental protection and others.

4.4 How to submit a notification

• In person to the postbox: at the CDV headquarters, Líšeňská 33a, 636 00 Brno

• By post: Transport Research Centre, v. v. i., Líšeňská 33a, 636 00 Brno (mark the envelope ‘NOTIFICATION UNDER THE WHISTLEBLOWER PROTECTION ACT’)

• By email: oznamovatel@cdv.gov.cz

• By telephone: +420 778 777 412

• In person: by prior arrangement via email oznamovatel@cdv.gov.cz

4.5 What information must a report contain to be valid and protected by law? It should include

• the whistleblower’s identification – first name, surname and date of birth or other information enabling unambiguous identification, contact details (email, telephone),

• a description of the unlawful conduct – what happened or is due to happen, when and where the conduct took place, who is alleged to have committed it (if known),

• reasonable belief in the truth of the report – the whistleblower must have sufficient grounds to believe that the facts stated are true,

• supporting documents or evidence – if available (e.g. documents, emails, photographs, witness statements).

The Whistleblower Protection Act does not apply to reports submitted anonymously.

4.6 Who handles the report

Your report is received and investigated by the designated internal contact person: Mgr. Iva Provalilová

4.7 Whistleblower protection

• If you act in good faith, you are protected by law – you must not be subjected to any retaliatory measures.

• The identity of the whistleblower is always strictly protected and will remain confidential. It will not be disclosed to any unauthorised person without their consent.

• Knowingly false reports may be subject to sanctions.

• The Whistleblower Protection Act does not apply to reports submitted anonymously.

4.8 External reporting system

If you do not wish to use our internal system, you may contact BDO Czech Republic, which provides an external reporting system for CDV – https://cdv.gov.cz/ochrana-oznamovatelu/

BDO Czech Republic’s external reporting system: https://www.bdo.cz

BDO Czech Republic provides an independent and professional assessment of reports and offers methodological and advisory support.

5 Evaluation of the internal anti-corruption programme

The aim of the evaluation is to improve the internal anti-corruption programme and to facilitate the coordination of anti-corruption activities.

The CDV prepares a report on the implementation of the internal anti-corruption programme as at 31 December of each odd-numbered calendar year and sends this report to the State Secretary of the Ministry of Transport by 31 January of the following year.

Task: Collection of data on the implementation of the MoT’s internal anti-corruption programme by subordinate organisations

The CDV shall provide the State Secretary with written information on the implementation of the internal anti-corruption programme, including any proposals for its update

Responsible: Head of the Legal Department or, where applicable, the Director of the institution

Deadline: by 31 January of every even-numbered calendar year

Anti-Corruption Program-2026 (DOCX; 588.39 KB)

Reports on the internal anti-corruption program

Zpráva o interním protikorupčním programu - 2021 (PDF; 166.71 KB)

Zpráva o interním protikorupčním programu - 2020 (PDF; 188.75 KB)

Zpráva o interním protikorupčním programu - 2019 (PDF; 570 KB)

Zpráva o interním protikorupčním programu - 2018 (PDF; 571.47 KB)

Zpráva o interním protikorupčním programu - 2017 (PDF; 174.13 KB)

Zpráva o interním protikorupčním programu - 2016 (PDF; 223.53 KB)

Zpráva o interním protikorupčním programu - 2015 (PDF; 167.6 KB)