Prevention of Corruption

The state, society and other parties expect from business transparent, ethical, and honest activities that produce the best results. AB Lietuvos geležinkeliai group of companies (hereinafter referred to as the LTG group of companies), in order to meet the expectations of these concerned parties, adheres to the principle of zero tolerance in its activities and has implemented a system of targeted anti-corruption measures.

The anti-corruption prevention implemented by the LTG group of companies is based on the principles of international standard ISO 37001:2016 ‘Anti-bribery management systems. Requirements and guidelines for use’ principles. ISO 37001:2016 certificate issued to LTG in 2022. Anti-corruption measures are implemented in accordance with the requirements of legal acts, taking into account the prevailing national and international practice, after assessing the risks associated with corruption. The anti-corruption policy of the LTG group of companies is the main document of the anti-corruption activities implemented in the Company, which defines the model for ensuring the anti-corruption and establishes the measures that must be implemented in order to achieve transparency and fairness.

The Anti-corruption system of the LTG group of companies is based on the leadership of managers. Managers are required to set a good example by their behaviour, act exclusively for the benefit of the interests of LTG group of companies and ensure that activities are carried out properly and transparently within the limits of their responsibility. All employees of the group are responsible for understanding, implementing, and applying the anti-corruption requirements related to their duties. The provisions of the Code of Ethics of the employees of the Company help to ensure the honesty, transparency, and reliability of LTG activities, as well as respectful mutual relations, while the Code of Ethics of the Suppliers gives sense to the transparent relationship between the LTG group of companies and its business partners.

LTG Group corruption resilience measures

Verification of the security clearance of persons applying for positions

Reconciling public and private interests and managing conflicts of interest

Investigation of fraud and other corruption

Risk assessment of legal and natural persons (operational partners)

Compliance with the requirements set out in the rules on gifts

Receiving reports of fraud, corruption or other unlawful acts by employees

Raising awareness of employees

Determining the likelihood of corruption

Ensuring the Reliability of Candidates and Employees

The list of positions in the group of companies of AB Lietuvos geležinkeliai for which a person shall be subject to a security clearance in order to be appointed has been approved

Pursuant to Article 17(5) of the Law on Prevention of Corruption of the Republic of Lithuania and the Order of the Director of the Special Investigation Service of the Republic of Lithuania of 10 November 2021 No. 2-231 on the approval of the description of the procedure for the submission of the information on the persons seeking or holding positions in the public sector entity, the European Union or the international institutions at the request of the Republic of Lithuania and the request to provide the information, point 2, a new list of positions in the AB Lietuvos geležinkeliai group of companies for which a person is required to undergo a security check in order to take up the position has been approved by the order of the CEO of AB Lietuvos geležinkeliai.

Determining the probability of the occurrence of corruption

Trust line

Any criminal offence being committed, committed or planned in the LTG Group, possible illegal acts or omissions of employees, abuse of office or other actions that may be indicative of a criminal offence of a corrupt nature may be reported and suggestions for corruption prevention measures may be made through the company’s established reporting channels:

Information on corruption cases can also be submitted to the Special Investigation Service of the Republic of Lithuania by phone +370 5 266 3333, by e-mail [email protected] or by leaving a message on the website www.stt.lt.

Reports received by the Trust Line are dealt with by AB Lietuvos geležinkeliai employees assigned by Business Resilience department. Notifications are dealt with within 20 working days of their receipt.

Anyone can submit a report anonymously, i.e. without giving their name and/or contact details. However, if contact details are provided and the person wishes to be informed of the outcome of the investigation, the whistleblower will be informed of the outcome of the investigation and the decisions taken in accordance with the established procedures.

The LTG Group shall ensure the confidentiality of the reporter and the data provided by the reporter, except in cases provided for by law.

Management of public and private interests

The LTG Group ensures the declaration of public and private interests and the management of conflicts of interest.

Candidates for relevant positions, the list of which is approved by LTG’s Chief Executive Officer, must be screened for potential conflicts of interest before they can assume a position within the LTG Group.

LTG Group employees file declarations of private interests in accordance with established procedures. Employees whose duties or functions are covered by the Law on the Harmonisation of Public and Private Interests of the Republic of Lithuania declare their private interests by submitting a declaration of private interests to the Register of Private Interests (PINREG).

Employees of the LTG group of companies who are not covered by the said law but who have a fixed computerised workstation are obliged to submit a declaration of private interests in accordance with internal regulations, and submit the declaration of private interests via the employee self-service module ManoLTG.

Semi-annual verification plans are drawn up each year for the verification of declarations submitted by LTG Group employees, to verify the declarations of private interests submitted and to prepare the semi-annual private interest verification reports.

All employees of the LTG Group are required to abstain from the drafting, discussion or adoption of decisions that may give rise to a conflict of interest. The resigning employee shall complete a resignation letter in the specified form, which shall be submitted to the immediate supervisor who shall approve or reject the resignation.

Receiving and giving gifts

The LTG Group has a zero-gift policy, which means that employees receive their salary and cannot receive any additional remuneration for carrying out their duties.

The approved Methodology of Receiving and Giving Gifts sets out guidelines for the behaviour of LTG Group employees in receiving and giving gifts, as well as principles for the behaviour of employees when participating in events and delegations. Gifts given, received or refused are recorded in the Register of Gifts.

Internal research

The LTG Group investigates possible fraud, corruption or other misconduct. The responsible Business Security Officers, upon receiving a report of possible fraud, corruption or other criminal offences, or upon discovering for themselves indications of a possible illegal activity in progress or committed, shall carry out an investigation in accordance with the Standard on the Verification and/or Investigation Process for Information Received. Facts identified in the course of the investigation that appear to constitute a criminal offence are passed on to law enforcement authorities.

Risk assessment of legal/natural persons

The LTG Group applies the Partner Integrity and Zero Risk Tolerance principles to prevent and manage potential corruption-related risks. The LTG Group works only with trusted partners and clients. Screening of prospective business partners, clients, reputation, solvency, sanctions and other considerations related to transparency is carried out.

Due diligence is a process that aims to further assess the nature and extent of corruption risks and to assist the LTG Group in its decision-making in relation to business partners and candidates/employees. It is an additional control tool to identify corruption risks, and it is the basis for the decision to develop relations with business partners and to decide on the credibility of a candidate/employee.

Raising employee awareness

LTG Group employees are obliged to continuously improve their competence in the prevention of corruption. Training in this area is divided into three groups: introductory, general and targeted (specific). The induction training must be completed within 6 months after the person is employed. General training is carried out periodically on the basis of a common training programme and is compulsory for all LTG Group employees.

Depending on the positions held by employees and the corruption risks or threats that may arise in those positions, various targeted and specialised anti-corruption training courses are organised on an as-needed basis for the LTG Group’s employees and for the employees performing the compliance function in order to continuously improve their knowledge and develop the skills required to perform their functions. This training model ensures the continuous development of management and the competences of employees in the area of corruption prevention.

The LTG Group also uses other forms of employee education and awareness-raising:

employees are made aware of the provisions of relevant legislation on corruption resilience processes;
participation in targeted training events: forums, seminars, conferences;
presentations on corruption resilience, suggestions on how to implement corruption resilience measures and strengthen the anti-corruption environment are prepared and presented;
relevant information is published on the LTG website.