BALTPOOL UAB and EPSO-G Group implements strategic projects of great importance to Lithuania, the success of which depends on the trust of the state, the public and the shareholder. Recognising this, the EPSO-G Group has put in place measures to help manage the risks of corruption that may arise in its operations. BALTPOOL UAB implements these measures in compliance with the requirements of the legislation of the Republic of Lithuania and in accordance with the Corruption Prevention Policy of the EPSO-G Group. It sets forth the main principles and requirements for the prevention of corruption in the EPSO-G group, along with the guidelines on how to ensure compliance with them:

• leadership of managers and involvement of employees – managers are directly responsible for the implementation of corruption prevention measures, and by their example and communication they instil a culture of zero tolerance for corruption in employees. Employees actively participate in corruption prevention training and are responsible for applying the provisions of the Corruption Prevention Policy in their day-to-day work;
• adherence to the highest standards of transparency and integrity;
• periodic assessment and management of corruption-related risks;
• implementation of targeted corruption prevention measures (such as balancing public and private interests and managing conflicts of interest, implementing procedures to ensure the credibility of staff, introducing internal whistleblowing channels, restrictions on the acceptance and presentation of gifts, requirements for transparent and ethical behaviour applied to employees and business partners, ensuring transparent public tenders and other measures).

BALTPOOL UAB main documents on corruption prevention activities are as follows (available in Lithuanian only):

• Anti-Corruption Policy;
• Policy on the Management of Interests;
• Anti-Corruption Policy for Employees;
• Code of Ethics for Employees;
• Supplier Code of Ethics;
• Description of procedures for the establishment and operation of whistleblowing channels;
• Description of procedures for conducting internal investigations.

The head of compliance and risk management of the “EPSO-G” Group, Romas Zienka, is responsible for the prevention of corruption and the implementation of the requirements of the Law on the Adjustment of Public and Private Interests in BALTPOOL UAB (e-mail: [email protected], phone: +370 612 58162).

DECLARATION OF PRIVATE INTERESTS AND MANAGEMENT OF CONFLICTS OF INTEREST

At BALTPOOL UAB, we ensure that employees declare their private interests and that potential conflicts of interest are managed. We have drawn up a list of job positions for which it is compulsory to declare private interests under the Law on the Adjustment of Public and Private Interests and, in order to provide clarity on the situations that may give rise to conflicts of interest, a list of activities where there is the greatest likelihood/risk of conflict of interest situations under the Law on the Adjustment of Public and Private Interests.

SECURITY CHECK OF STAFF

BALTPOOL UAB is committed to employing people of good repute and, in accordance with the Law on the Protection of Objects of Importance to Ensuring National Security and the Law on Prevention of Corruption, we carry out a security check on people who wish to join our company.

In accordance with the Law on Prevention of Corruption, a list of job positions for which the selected candidates are subject to security check is drawn up. The approved list of job positions can be consulted here.

ACCEPTANCE AND PRESENTATION OF GIFTS

BALTPOOL UAB does not tolerate any gifts given in connection with employment or job position, except for those permitted under the EPSO-G Group’s Corruption Prevention Policy. Employees must not accept any gifts of money, gift vouchers or alcoholic beverages, including gifts of low value, if the circumstances in which they are given or accepted could lead to a misunderstanding or contradiction and create the appearance of a conflict of interest.

BALTPOOL UAB staff members record gifts received in the register of gifts received by staff members the register of gifts you can find here.

TRUST LINE

We encourage our staff members to report possible corrupt practices through our internal whistleblowing channel, the Trust Line. For more information on the Trust Line and the possible ways to report corrupt practices, please click here.

LIKELIHOOD OF CORRUPTION

In accordance with Article 10 of the Law on Prevention of Corruption, BALTPOOL UAB may carry out an assessment of the likelihood of corruption. The likelihood of corruption is the assumption that certain external, internal or individual risk factors affecting the company’s activities will create opportunities for corruption to occur. The likelihood of corruption and measures to reduce or eliminate the risk of corruption shall be identified in order to establish and eliminate or manage corruption risk factors.

In recent years, BALTPOOL UAB has not identified any situations that could be named as examples of corruption.