Governance
Anti-corruption activities
Key commitments
The EPSO-G Group implements strategic projects of national importance, the success of which depends on the trust of the state, society and its shareholder. Recognising this, the EPSO-G Group implements measures to help manage potential corruption risks arising in its activities. EPSO-G implements these measures in compliance with the laws and regulations of the Republic of Lithuania and in accordance with the EPSO-G Group Anti-Corruption Policy. The policy sets out the key commitments, the most important of which are as follows:
Leadership and employee engagement – leaders are directly responsible for the implementation of anti-corruption measures, instilling a culture of zero tolerance for corruption through their example and communication with employees. Employees actively participate in anti-corruption training and are responsible for applying the provisions of the Anti-Corruption Policy in their daily activities.
Compliance with the highest standards of transparency and integrity.
Periodic assessment and management of corruption-related risks.
Implementation of targeted anti-corruption measures – reconciliation of public and private interests and management of conflicts of interest, implementation of procedures to ensure personnel integrity, establishment of internal channels for reporting violations, restrictions on the acceptance and giving of gifts, requirements for transparent and ethical conduct by employees and business partners, ensuring transparent public procurement, and other measures.
The anti-corruption prevention model implemented by the EPSO-G Group is based on the principles of the international standard ISO 37001:2016, “Anti-bribery management systems – Requirements with guidance for use”. At the end of 2024, EPSO-G was issued a certificate confirming compliance with the requirements of this standard.
Key documents of "EPSO-G" anti-corruption activities
Additionally, these documents:
- Description of procedures for the establishment and operation of whistleblowing channels;
- Description of procedures for conducting internal investigations.
Declaration of private interests and management of conflicts of interest
At “EPSO-G”, we ensure that employees declare private interests and manage potential conflicts of interest. We have established a list of positions for which individuals are required to declare private interests according to the Law on Balancing Public and Private Interests, and to provide clarity on what situations may lead to conflicts of interest – a list of areas of activity where there is the highest likelihood (risk) of situations defined by the law arising.
Employee reliability checks
We aim for “EPSO-G” to employ individuals of impeccable reputation, therefore, following the Law on the Protection of Objects Important for National Security and the Anti-Corruption Law, we conduct reliability checks on individuals wishing to be employed by “EPSO-G”.
According to the Anti-Corruption Law, a list of positions for which selected candidates undergo reliability checks has been established.
Acceptance and giving of gifts
“EPSO-G” does not tolerate any gifts given due to work or positions held, except for gifts that are allowed under the “EPSO-G” group of companies’ Anti-Corruption Policy. Employees are prohibited from accepting any gifts in cash, gift vouchers, or alcoholic beverages, as well as low-value gifts if the circumstances of giving or receiving them could be interpreted ambiguously, evaluated controversially, and create the appearance of a conflict of interest.
“EPSO-G” employees register received gifts in the Employee Gift Register.
Trust Line
“EPSO-G” group values that you feel safe and can report any inappropriate actions by employees or partners. Therefore, the Trust Line operates – an opportunity to anonymously and confidentially report possible violations, helping to prevent and expose violations.
What information can you report?
- corruption, bribery, fraud, or other dishonest behavior
- violations of procurement, data protection, asset use, or other rules
- harassment, violence, discrimination, or other inappropriate behavior
- violations of employee safety, health, or environmental requirements
- partner behavior that does not meet ethical requirements
- violations of security or use of artificial intelligence systems.
A person wishing to submit a report can do so in the following ways
- Mail
„EPSO-G“, Laisvės pr. 10, Vilnius. Indicate on the envelope: "Confidential notice, do not open envelope."
- Contact
To Lina Matukaitė, acting Group Head of Compliance Management at EPSO-G.
How will reports be handled?
- your report will be processed confidentially
- it will be reviewed only by authorized specialists
- we will usually provide a response within 30 days.
Probability of corruption occurrence
According to Article 10 of the Anti-Corruption Law, “EPSO-G” may conduct an assessment of the probability of corruption occurrence. The probability of corruption occurrence is the assumption that certain external, internal, or individual risk factors affecting the company’s activities will create opportunities for corruption to arise. To identify and eliminate or manage corruption risk factors, the probability of corruption occurrence is determined, and measures to reduce or eliminate corruption risk are established.
In recent years, the probability of corruption occurrence has not been assessed at “EPSO-G”.
Internal reporting channel
Below is information on how you can provide information about possible violations occurring in UAB “EPSO-G” (hereinafter – the Company) using the internal reporting channel (hereinafter – the Channel) according to the Law on the Protection of Whistleblowers of the Republic of Lithuania (hereinafter – the Law).
A violation is considered to be a possible criminal act, administrative offense, or violation of work duties that may be prepared, committed, or done in the Company, as well as a gross violation of mandatory professional ethics norms, an attempt to conceal the mentioned violation, or any other violation of law that poses a threat to the public interest, about which the person providing information about the violation learns from their existing or potential employment or contractual relationships with the Company or during employment or other pre-contractual relationships (hereinafter – Violation).
Information about Violations is provided to protect the public interest. You can provide information about violations through the internal reporting channel.
- danger to public safety or health, personal life or health;
- danger to the environment;
- obstruction or illegal influence on investigations or courts conducted by law enforcement agencies in the pursuit of justice;
- financing of illegal activities;
- illegal or non-transparent use of public funds or property;
- illegally acquired property;
- concealment of the consequences of a violation, obstruction of determining the extent of the consequences;
- violations of competition law and state aid rules;
- violations of international sanctions implemented in the Republic of Lithuania or restrictive measures provided for in the laws of the Republic of Lithuania;
- other violations that infringe on the public interest.
A person providing information about a violation through the internal channel does not have to be completely convinced of the truth of the reported facts, nor does he have the obligation to assess whether the violation he reports meets the characteristics of criminal acts or other legal violations as defined in the laws.
A person wishing to submit a report under the Law can do so in the following ways
- By mail
By delivering or sending by post to the Company (at the address “EPSO-G”, Laisvės pr. 10, Vilnius) a completed violation report form. When sending the report by post, the marking “FOR THE COMPETENT ENTITY PERSONALLY” must be placed on the envelope containing the information about the violation, below the addressee’s name;
- Verbally
Upon arrival at the Company (at Laisvės Ave. 10, Vilnius) to the competent entity;
- By email
When submitting information about a violation, please fill out the report form and send it via the Company’s internal reporting channel – the email address ;
- By contacting
Apply to the Prosecutor General’s Office – the competent authority.
We recommend submitting reports after filling out the report form. Reports can also be submitted in free form, but they must include the following information:
- who, when, how, and what violation was committed, is being committed, or is planned to be committed, etc.;
- the date and circumstances of learning about the violation;
- your name, surname, personal code, workplace, and other contact details;
- if possible, provide any available documents, data, or information revealing signs of a possible violation.
Individuals providing information about violations: rights and guarantees
Individuals who provide information about violations are ensured confidentiality and prohibition of negative impact against them from the moment the report is received, regardless of whether the person who submitted the report about the violation in the Company has been recognized as a whistleblower or not.
It is not necessary to ensure confidentiality when:
- the person providing information about the violation requests it in writing;
- the information provided by the person reporting the violation is known to be false.
A person does not incur any contractual or tort liability for providing information about a violation, nor liability for defamation or insult to honor and dignity, if, when providing information about a violation in accordance with the procedure established by the Law, he reasonably believed that he was providing accurate information.
A person is liable for damage caused by the provision of information about a violation only if it is proven that the person could not reasonably believe that the information they provided was correct.
The provision of knowingly false information, as well as information that constitutes a state or service secret, does not provide the person with guarantees under the Law. A person who has provided knowingly false information or disclosed a state or service secret or professional secret is liable in accordance with the law.
Handling of reports
Reports received by the Company are examined in accordance with the Law and other legal acts.
Currently, the Company’s internal legal acts regulating the examination of reports are being updated.