Who can submit information about possible infringements?
The Trust Line is an open channel for all natural or legal persons, whether current or former employees of EPSO-G and other companies in the Group, former or potential suppliers, contractors or communities.
You always have the option of reporting information anonymously.
Who do I contact if I am considering reporting or have reported an infringement?
If you are considering submitting, or have already submitted, information about an infringement, you can seek advice:
- Anonymously - by filling in the reporting form;
- By email - [email protected];
- Contact UAB EPSO-G’s Director for Compliance and Risk Management, Romas Zienka, by phone at +370 612 58162 or by email at [email protected].
What are the possible infringements we are inviting you to report?
- Acts of a corrupt nature, including but not limited to: bribery, influence peddling, or other abuse or neglect of duty by staff members; fraud and deceit; breaches of the rules on declaration of private interests (e.g. cases of nepotism and cronyism), breaches of and lack of compliance with the Corruption Prevention Policy;
- Cases of non-compliance, including but not limited to: procurement infringements on behalf of the Group, including breaches of transparency, equality, non-discrimination, proportionality and impartiality requirements, unlawful or non-transparent use of the Company’s assets and property, breaches of the personal data of the Company’s employees and other personal data handled by the Company, anti-competitive practices, breaches of physical security, breaches of the management of confidential information, etc.;
- Occupational health and safety violations, including but not limited to occupational health and safety of workers; fire safety violations, etc.;
- Environmental violations, including but not limited to: environmentally damaging behaviour by Group company employees and/or contractors, breaches of environmental requirements, etc.;
- Conduct by Group company employees that violates the provisions of the Code of Ethics and/or the Equal Opportunities Policy, including, but not limited to: conduct that constitutes discrimination, sexual harassment, psychological violence, etc.;
- Conduct by contractors or partners that violates the Supplier Code of Conduct, including but not limited to: fraud, abuse of position, breach of contractual obligations, etc.
Who is responsible for assessing and following up the information you submit?
The information contained in the reports is assessed by staff of the Compliance and Risk Management Department; where necessary, other experts are brought in. Responsible person - Romas Zienka, Director for Compliance and Risk Management at EPSO-G, tel.: +370 612 58162, email [email protected].
What actions are taken on receipt of information?
Acknowledgement of receipt. On receipt of your report, we will register and acknowledge receipt of the information no later than 2 working days after receiving it.
N.B.! The information you have submitted may be forwarded to a competent authority without your consent within 2 working days of receipt, with notice to you after the fact, if we determine that:
- The company is not competent to properly evaluate your information, or:
- The content of the information received will give rise to a reasonable belief that a criminal offence or an administrative offence is being planned, committed or has already been committed.
Initial assessment. No later than 10 working days after the aforementioned acknowledgement, an initial assessment of the information you have submitted will be carried out and one of the following decisions will be adopted:
- To examine the information contained in the report in detail in accordance with the procedures set out in the Company’s internal documents;
- Not to examine the information about the Infringement if the following circumstances exist or are established:
- The information about the Infringement is based on facts that are undeniably untrue and does not conform with reality;
- The information is abstract, based on general statements or personal opinions of the Whistleblower that cannot be verified;
- The report is made repeatedly regarding the same circumstances, after the information about the Infringement has been investigated and decided upon;
- The information on the Infringement is being handled by another authority.
Informing on further steps to be taken. You will be informed no later than 10 working days after acknowledgement of the receipt of the report:
- If it has been decided to examine the information you have submitted in detail; on the status of the examination of the information you have submitted (the steps planned or taken, the reasons for them and the important dates);
- If it has been decided not to examine the information submitted; the main reasons for that decision;
- If it has been decided to refer the information you submitted to a competent authority; the specific authority to which your report was referred.
Informing on the outcome of the investigation. Once the examination of the information submitted has been completed and the conclusions and recommendations of the internal investigation have been confirmed, you will be informed in writing within no more than 2 working days of:
(i) The outcome of the examination and the decision taken (once the infringement has been established, the liability of the persons responsible for the infringement shall be notified);
(ii) The actions taken or planned to prevent the recurrence of the infringement;
(iii) The procedure for appealing against the decision taken, if such a decision may be appealed.
This information is provided only to the extent that it does not conflict with other legislation on data and information protection.
How long can a thorough examination of the information I have submitted take?
Once the decision has been made to carry out an internal investigation on the basis of the information received, it shall be carried out within the shortest possible time, but not more than 30 (thirty) calendar days.
However, taking into account the complexity of the internal investigation, as well as additional circumstances which have come to light during the course of the investigation and other objective reasons, a decision may be taken to extend the investigation for a maximum of an additional 30 calendar days, for as many times as he objective circumstances exist.
How are we committed to ensuring the confidentiality of the information you submit?
All information submitted by you, including your identity and contact details, shall be classified as confidential information of the Company, unless the information is public.
We undertake to ensure that the information submitted by you, including your identity and contact details and any additional documents submitted by you, is stored and processed by implementing organisational, technical and software measures that ensure the protection of the information submitted against unauthorised destruction, alteration, disclosure, accidental loss, unauthorised direct or indirect access or other unlawful processing.
- Confidentiality is not guaranteed if you yourself give a permission in writing to publicise the information you have submitted, or if the information submitted is knowingly false;
- Providing your data and other information to the competent authorities investigating a pre-trial investigation or other irregularities without disclosing it within the Company shall not be considered a breach of confidentiality.