Who can provide information about possible infringements?
The Helpline is an open channel for all natural or legal persons, whether current or former employees of Tetas UAB, former or potential suppliers, contractors or communities.
You always have the option to report information anonymously.
Where do I go 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];
- Please contact UAB EPSO-G’s Director of Compliance and Risk Management, Romas Zienkas, by phone 8 612 58162, e-mail. [email protected].
What are the possible infringements we are inviting you to report?
- Corrupt acts, including but not limited to: bribery, bribery, influence peddling, or other corrupt acts of abuse or neglect of duty by staff; fraud and deceit; breaches of the rules on declaration of private interests (e.g. cases of nepotism and cronyism), breaches and deficiencies in the Corruption Prevention Policy;
- Non-compliance, including but not limited to: breaches of the Group’s procurement practices, including breaches of transparency, equality, non-discrimination, proportionality and fairness requirements, illegal 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, restrictive conduct, breaches of physical security, breaches of the management of confidential information etc.;
- Occupational health and safety violations, including but not limited to occupational safety and health; 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 employees of a Group company that violates the provisions of the Code of Conduct 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 office, breach of contractual obligations, etc.
Who is responsible for assessing and following up the information you submit?
The information contained in the notifications is assessed by staff from the Compliance and Risk Management Unit and, where necessary, other experts are brought in. The person responsible is Romas Zienka, Director of Compliance and Risk Management at EPSO-G, tel.: 8 612 58162, e-mail : [email protected].
What action is taken on receipt of information?
Acknowledgement of receipt. Upon receipt of your message, we will record and acknowledge receipt of the information no later than 2 working days after receiving it.
N.B.! The information you have provided may be forwarded to a competent authority without your consent within 2 working days of receipt, with notice to you, if we determine that:
- The company is not competent to evaluate your information properly; or
- the content of the information received will give rise to a reasonable belief that a criminal offence or administrative offence is being prepared, committed or committed.
Initial assessment. No later than 10 working days after approval, it will carry out an initial assessment of the information you have provided and take one of the following decisions:
- to examine the information contained in the notification in detail in accordance with the procedures set out in the Company’s internal documents;
- not to investigate the information about the Infringement if the following circumstances exist or are established:
- the information about the Infringement is based on facts that are manifestly untrue;
- the information is abstract, based on general statements or personal opinions of the Whistleblower which cannot be verified;
- reapplying for the same circumstances after the previous information about the Infringement has been investigated and decided;
- the information on the Infringement is dealt with by another authority.
Informing on next steps. You will be informed no later than 10 working days after confirmation of the notification:
- if a decision is taken to examine the information you have submitted in detail, the status of the examination of your submission (the steps planned or taken, the reasons for them and the time limits);
- if a decision is taken not to examine the information submitted, the main reasons for that decision;
- if the decision is taken to refer the information you submitted to a competent authority, the specific authority to which your report was referred.
Communicating the results of the study. Once the conclusions and recommendations of the internal investigation have been finalised, you will be informed in writing of the following within 2 working days at the latest:
(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 action 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 it take to fully examine the information I have provided?
Once an internal investigation has been decided on the basis of the information received, it shall be carried out as soon as possible, but within a maximum period of 30 (thirty) calendar days.
However, taking into account the complexity of the internal investigation, 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 the objective circumstances exist.
How are we committed to ensuring the confidentiality of the information you provide?
All information provided 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 provided by you, including your identity and contact details and any additional documents provided by you, is stored and processed by implementing organisational, technical and software measures that ensure the protection of the information provided against unauthorised destruction, alteration, disclosure, accidental loss, unauthorised direct or indirect access or other unlawful processing.
However:
- confidentiality is not guaranteed when you yourself request it in writing or if the information provided is knowingly false;
- Providing your data and other information to the competent authorities investigating a pre-trial investigation or other irregularities without disclosing it to the Company shall not be considered a breach of confidentiality.
Reports we have received and investigated
2022 m. Statistics on reports received and investigated by companies in the UAB Tetas Group.