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Internal Messaging Channel

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    Below is information on how you, using the internal whistleblowing channel of Tetas, may provide information about violations of law prepared, committed or committed in Tetas in accordance with the Law on the Protection of Whistleblowers of the Republic of Lithuania.

    The Law on the Protection of Whistleblowers of the Republic of Lithuania
    A breach is deemed to be a criminal offence, an administrative offence or a breach of employment duties that Tetas may be preparing, is being committed or has been committed by Tetas, as well as a gross breach of mandatory standards of professional ethics, an attempt to conceal such a breach, or any other legal violation that poses a threat to or infringes upon the public interest, where the person reporting the breach becomes aware of such information through their existing or prospective employment or contractual relationship with the company, or during recruitment or other pre-contractual relations. Information about breaches is provided in the public interest. You can use the internal reporting channel to report breaches relating to:
    1. a threat to public safety or health, or to a person’s life or health;
    2. environmental risk;
    3. obstruction of, or unlawful interference with, investigations carried out by law enforcement authorities or the administration of justice by the courts;
    4. the financing of unlawful activities;
    5. the unlawful or non-transparent use of public funds or assets;
    6. property acquired unlawfully;
    7. concealing the consequences of the offence committed, or obstructing the determination of the extent of those consequences;
    8. breaches of competition law and state aid rules;
    9. a breach of international sanctions implemented in the Republic of Lithuania or of restrictive measures provided for in the legislation of the Republic of Lithuania;
    10. other offences that undermine the public interest.
    A person providing information about a violation through an internal channel is not required to be completely certain about the accuracy of the reported facts, nor is he or she obliged to assess whether the violation being reported meets the criteria for criminal offenses or other violations of the law as defined in legislation.

    Important

    Trust line
    1. The internal reporting channel is not intended for the submission of complaints, requests or reports made solely to protect personal interests. Reports made solely to protect personal interests will not be considered;
    2. If you wish to report any breaches other than those specified above, please use the Whistleblowing Hotline. Reports received via the Whistleblowing Hotline will not be regarded as reports submitted under the Law on the Protection of Whistleblowers of the Republic of Lithuania.

    Reporting an infringement

    Violation Report Form

    A person wishing to submit a notification under the Law on the Protection of Whistleblowers of the Republic of Lithuania may do so in the following ways:

    1. by contacting the competent body at Tetas directly in writing, either by hand-delivering or posting a completed breach notification form to Tetas (at V. Krėvės pr. 120, LT-51119 Kaunas). When sending the report by post, the envelope containing the information regarding the breach must bear the mark ‘TO THE COMPETENT AUTHORITY PERSONALLY’ below the addressee’s name;
    2. in person, by visiting Tetas (at 120 V. Krėvės Avenue, LT-51119 Kaunas) to speak to a competent representative;
    3. by submitting information about a breach, having completed the reporting form, via the Company’s internal channel for reporting breaches – email: [email protected];
    4. by applying to the Prosecutor General’s Office, the competent authority. The notification shall be submitted to the Prosecutor General’s Office when:
      • the infringement is of substantial importance to the public interest;
      • it is essential to prevent or put a stop to the infringement as soon as possible, as significant damage may result;
      • persons in management positions who are linked to Tetas through employment or contractual relationships may themselves be committing or may have committed breaches;
      • information regarding the breach was reported via the internal whistleblowing channel, but no response was received, or no action was taken in response to the information provided, or the measures taken were ineffective;
      • there are grounds for believing that, if information about a breach is reported via the internal breach reporting channel, the whistleblower’s anonymity or personal confidentiality may not be guaranteed, or that attempts will be made to cover up the reported breach;
      • Tetas does not have an operational internal channel for reporting breaches;
      • The individual cannot use the internal whistleblowing channel because they no longer have any employment or other legal relationship with Tetas.

    We recommend that you submit reports by completing the breach notification form. Reports may also be submitted in free-form, but they must include the following information:

    1. who, when, how and what offence has been, is being or is about to be committed, and so on;
    2. the date on which the breach was discovered and the circumstances surrounding it;
    3. your first name, surname, personal identification number, place of work and other contact details;
    4. where possible, provide any available documents, data or information indicating signs of a possible breach.

    At Tetas, the role of competent person has been assigned to the Head of Prevention, Vitalijus Latypovas (email: [email protected], tel: +370 654 80868).

    Vitalijus Latypovas

    Prevention Manager

    Email: [email protected]

    Tel: +370 654 80868

    Rights and guarantees of persons providing information on breaches

    From the moment of receipt of the notification, the confidentiality of the person and the prohibition of exerting a negative impact on them shall be ensured to the persons who have provided information about the violations, regardless of whether the person who submitted the notification of the violation to the company has been recognized as a whistleblower or not. Confidentiality is ensured regardless of the results of the investigation of the information on the breach received. Confidentiality is not necessary where:
    1. the person providing information about the infringement requests this in writing;
    2. the information provided by the person reporting the breach is known to be false.
    A person shall not incur any contractual or tortious liability, nor shall they be liable for defamation or an attack on honour and dignity, or for defamation, provided that, when providing information about the infringement in accordance with the procedure laid down in the Law on the Protection of Whistleblowers of the Republic of Lithuania, they reasonably believed that they were providing accurate information. A person shall be liable for damages caused by the provision of information about the violation only if it is proved that the person could not reasonably believe that the information provided by him was correct. The submission of knowingly false information, as well as information constituting a state or official secret, does not provide guarantees to a person under the Law on the Protection of Whistleblowers of the Republic of Lithuania. A person who has provided knowingly false information or has disclosed a state or official secret or professional secret shall be liable in accordance with the procedure established by legal acts.

    Handling of reports

    Reports received by Tetas are examined in accordance with the procedures laid down in the Law on the Protection of Whistleblowers of the Republic of Lithuania and other legislation.

    The company is currently updating its internal regulations governing the handling of reports.

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