Business conduct

Corruption prevention

Ignitis Group is committed to acting in a responsible and sustainable manner and therefore does not tolerate any form of corruption in its day-to-day operations, and is committed to doing business with integrity and transparent communication with all stakeholders.

We ensure this by adhering to the Group's Anti-Corruption Policy

Anti-Corruption Policy
The Group's guiding document for the creation of an anti-corruption environment, setting out the applicable principles and obligations for the creation of a transparent environment, as well as the implementation, supervision and control of the Policy.

In accordance with the provisions of the Anti-Corruption Policy, the Group's companies undertake:

Not tolerate unethical behaviour, illegal gifts, nepotism, conflicts of interest, bribery, swindling, influence peddling, abuse and other corruption offences, as well as the less dangerous forms of corruption;

To refrain from exercising any form of influence, whether direct or indirect, over politicians or political parties, and to refrain from financing or otherwise providing support to politicians, political parties/movements, their representatives or their candidates, election campaigns, foundations established by politicians (or persons related to politicians), or any other organisations.

To comply with the requirements of international legal acts, as well as legislation of the Republic of Lithuania and other countries in which the Company operates in the field of corruption prevention and the anti-corruption management system implemented by the Company.

The Anti-Corruption Policy establishes common principles and commitments for a transparent environment:

1. Legality: the Group creates a transparent and corruption-proof environment in accordance with the requirements of the Anti-Corruption Management System, the Code of Ethics, this Policy and other legal acts.
2. Zero tolerance for corruption: the Group does not tolerate any form of corruption or corrupt practices. This principle applies in relations with both the public and private sectors.
3. Principle of avoiding conflicts of interest: all employees of the Group must perform their duties honestly, without using their current duties for personal or family benefits, and without performing activities harmful to the Group's or public interests in any other way.
4. Principle of operational transparency: The Group ensures disclosure and transparency of information and seeks to make the Group's key documents publicly available, ensuring adequate disclosure of information.
5. Zero-gift policy: within the Group, we refrain from providing any Gifts to operational partners, except where required by normal international protocol. The Group does not tolerate any Gifts or hospitality that could be construed, directly or indirectly, as rewards, influence, patronage.

Group Anti-Corruption Policy
Group Code of Ethics

Creation of anti-corruption environment

Companies of Ignitis Group operate a unified Anti-Corruption Management System (ACMS), developed in accordance with the international standard LST ISO 37001:2017 (identical to ISO 37001:2016) “Anti-Corruption Management Systems. Requirements and Guidelines for Use” (hereinafter referred to as the standard).

In 2021, Ignitis Group underwent its first certification audit and was issued with an ISO certificate, which confirmed the compliance of the Group's ACMS with the requirements of the standard.

The Group's compliance with the standard has been assessed annually by independent external auditors.

In 2024, a re-certification by a team of external auditors confirmed that the organisation's overall management system is effective and complies with the requirements of the standard, and an ISO 37001 certificate was issued.

The following elements of the ACMS are in place at Ignitis Group:

• Carrying out a corruption risk assessment.
• Compliance function to monitor system performance.
• Informing relevant stakeholders (employees, suppliers, business partners) about the Anti-Corruption Policy.
• Development and training of employees and business partners.
• Monitoring areas of increased risk of corruption.
• Implementation of control mechanisms to reduce the risk of corruption.
• Establishment of procedures to ensure that employees or other relevant parties can effectively report cases of corruption.
• Establishment of a process to investigate and address any allegations of possible or suspected bribery.

Anti-corruption management measures in the Ignitis Group

Key measures applied in all Group companies:

• Code of Ethics, Anti-Corruption Policy of the Group
• Basic anti-corruption training for employees
• Gift and hospitality management
• Management of conflicts of interest: declaration of private interests, withdrawal
• Risk assessment of corruption in relevant positions
• Diligent screening of candidates and employees, ensuring credibility
• Trust Line
• Internal investigations

Additional measures to be taken as needed to assess potential corruption risks:

• Corruption risk assessment for operational areas
• Due diligence of transactions and business partners (before concluding contracts)
• Anti-corruption control measures and obligations implemented by business partners
• Financial and non-financial control measures
• Additional anti-corruption training for employees
• Additional anti-corruption training for business partners

Gift policy

Ignitis Group conducts its business in accordance with the highest ethical standards and principles, guided by standards of openness and honesty. We aim to create a responsible and sustainable business culture in the energy sector.

We value transparent cooperation based on trust, partnership and respect, and believe that the best gift is sincere thanks and attention. Therefore, we refrain from making any gifts to our business partners within the Group and do not accept any gifts except for:

• gifts and hospitality when required by customary international protocol practices (international protocol is understood as the set of generally accepted rules and traditions on which governments, foreign services, diplomatic missions, officials, etc., base their interactions);
• cases of gift-giving during official and/or public events, where a gift is given to an employee and/or group of employees of the Group, as representative(s) of the Group, in public view of other participants of the event (e.g., a gift is given to the Company on the occasion of the celebration of the Lithuanian Energy Workers’ Day; a gift is given to the Company in appreciation of a specific activity/accomplishments/performance in a particular area, etc.).

We urge our business partners not to give any gifts to our Group employees. In order to thank our Group's employees, we encourage you to express your gratitude with kind words and attention rather than gifts of material value.

All gifts received or given shall be recorded in the Group's gift register.

Group Gift Standard

Trust line

The Trust Line is an anonymous and confidential way to report violations of the law by Ignitis Group employees or business partners that threaten or violate the public interest and to ensure the prevention and detection of such violations.

The Trust Line as a means of reporting potential violations is set out in the Ignitis Group Code of Ethics, the Group's Anti-Corruption Policy, the Sustainability Policy, the Environmental Policy, the Policy of Equal Opportunities and Diversity.

Trust Line contact details

You can report suspected violations by:

• Filling in this form: Reporting to the Trust Line
• E-mail: [email protected]
• Leaving a message on the Trust Line answering machine by calling tel. No. +370 640 88889
• Sending by ordinary mail to: Vilnius city municipality, Laisvės Ave. 10, 04215 Vilnius. Please indicate the recipient on the envelope: UAB Ignitis grupės paslaugų centras, Business Safety and write: confidential, do not open envelope.
• Notifications of an violations may be made in person to the Competent Entity of the Group of Companies. Information provided in person can only be made available during the Group's official business hours;
• Complete and submit a violation notification in the form prescribed by Law, or report a violation in free form

You can also report cases of corruption:
to the Special Investigation Service of the Republic of Lithuania,
Prosecutor's Office of the Republic of Lithuania.

The Trust Line is intended for reporting:

• Violations of the Group's Anti-Corruption Policy;
• Activities of corruption (abuse of office, bribery, swindling or other acts);
• Fraud and deception;
• Violations of the rules on declarations of private interests;
• Violations in carrying out public procurement;
• Violations of the handling of confidential information;
• Occupational safety violations (drunk employees, etc.);
• Misconduct (fraud, abuse of office, etc.) by contractors or business partners
• Illegal or non-transparent use of the Company's funds or assets;
• Concealment of the consequences of the violation, obstruction of the determination of the extent of the consequences;
• Any form of discrimination (based on age, gender, nationality, religion, sexual orientation, etc.), as well as any form of harassment, violence and bullying.
• Any other suspected misconduct or potential misconduct inconsistent with the Group's Code of Ethics and the Group's Anti-Corruption Policy.

We undertake to guarantee the anonymity of whistleblowers and the confidentiality of the information they provide.

All reports received through the Trust Line shall be dealt with in accordance with the provisions of the Group's Standard for the Establishment and Operation of Internal Whistleblowing Channels.

The Trust Line cannot be used to make false accusations, nor can it be used for commercial or other general issues.

Statistics on notifications received through the Trust Line

Whistleblower protection

WE ENSURE WHISTLEBLOWER PROTECTION WITH THE GROUP

The Law on the Protection of Whistleblowers (hereinafter referred to as the Law) establishes a mechanism for the protection of persons who have provided information about an irregularity in an institution with which they have, or have had, a service, employment or contractual relationship.

The Law also establishes the rights and obligations of persons who report violations in the institutions, the grounds and forms of their legal protection, as well as measures for the protection, encouragement and assistance of such persons, in order to enable them to adequately report violations of the law that threaten or violate the public interest, and to ensure the prevention and disclosure of such violations.

Who can provide information about possible violations?

The Group's Trust Line (an internal information channel) is available to any natural person or legal entity.

The Trust Line (internal information channel) may be used by any natural person who provides information in accordance with the Law about a violation within the Group, which he/she becomes aware of as a result of his/her service, employment or contractual relationship with the Ignitis Group of Companies.

A person who does not have, and has not had, any relationship with the Group (whether employment, contractual or otherwise) The Trust Line may also provide information, but its assessment and treatment shall be carried out in accordance with the Group's legal acts and not the Law.

Where to report violations?

You can report suspected violations by:

• Filling in this form:  Reporting to the Trust Line
• E-mail [email protected]
• Leaving a message on the Trust Line answering machine by calling tel. No. +370 640 88889
• Sending by ordinary mail to: Vilnius city municipality, Laisvės Ave. 10, 04215 Vilnius. Please indicate the recipient on the envelope: UAB Ignitis grupės paslaugų centras, Business Safety and write: confidential, do not open envelope.
• Notifications of an violations may be made in person to the Competent Entity of the Group of Companies. Information provided in person can only be made available during the Group's official business hours;
• Complete and submit a violation notification in the form prescribed by Law, or report a violation in free form

In accordance with the Law, a person can report the following cases that are being prepared for, being committed or have been committed:

• criminal offence;
• administrative offence;
• official misconduct; or
• violation of employment obligations;
• as well as serious violations of mandatory standards of professional conduct;
• or any other offence that threatens or violates the public interest.

In accordance with the Law, information on violations shall be provided in relation to:

1. risk to public safety or health or a person’s life or health;
2. environmental hazard;
3. obstruction or unlawful influence over the investigations carried out by law enforcement institutions or over the courts in the administration of justice;
4. financing of illegal activities;
5. illegal or non-transparent use of public funds or assets;
6. illegally acquired assets;
7. concealment of the implications of a committed wrongdoing or obstruction of the scope of implications being identified;
8. other offences.

In accordance with the Law, a person may provide information about a violation:

1. at the establishment through the internal violation reporting channel;
2. directly to the competent authority (prosecutor's office);
3. publicly.

When is it advisable to contact the prosecutor’s office?

When a person becomes aware of signs of a criminal offence that may have been committed or is about to be committed, we recommend making a report directly to the prosecutor's office. A person should contact the prosecutor’s office directly if any of the following circumstances apply:

1. The violation is of substantial importance for the public interest;
2. It is necessary to prevent or stop the violation as soon as possible, as serious damage could result therefrom;
3. Persons having a managerial, employment, service or contractual relationship with the institution may themselves be committing or have committed violations;
4. Information about a violation was submitted through an internal whistleblowing channel, but no response was received or no action was taken in response to the information submitted or the measures taken were ineffective;
5. There are grounds for believing that the anonymity of the whistleblower or the confidentiality of the person reporting the violation may not be ensured, or that the reported violation will be concealed, by submitting the information on the violation through an internal whistleblowing channel;
6. The institution does not have an internal whistleblowing channel in place;
7. The person is unable to use the internal whistleblowing channel because he/she no longer has an employment, service or other legal relationship with the institution.

WHO IS RESPONSIBLE FOR ASSESSING AND FOLLOWING UP THE INFORMATION YOU PROVIDE?

The Trust Line (an internal whistleblowing channel) is managed by the Group's corporate security department. The information contained in the reports shall be assessed by the Group's authorised corporate safety officer(s) and, if necessary, other experts shall be involved.

All reports received through the Trust Line shall be dealt with in accordance with the provisions of the Group's Standard for the Establishment and Operation of Internal Whistleblowing Channels.

Assurance of confidentiality

All information provided to the Trust Line (violation reporting channel), including your personal identity and contact details, shall be classified as confidential information.

We undertake to ensure that the information you provide is stored and processed by implementing organisational, technical and software measures to protect the information provided against unauthorised destruction, alteration, disclosure, accidental loss, unauthorised direct or indirect access, or other improper processing.

The confidentiality requirement shall not apply where:

• the person submitting or providing information about the violation so requests in writing;
• the person provides knowingly false information.

Legislation relevant to whistleblowers

Republic of Lithuania Law on the Protection of Whistleblowers

More information on whistleblower protection

Candidate security clearance

In order to ensure that Ignitis Group employs people of impeccable reputation, 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 due diligence checks on candidates who wish to apply for certain positions at Ignitis Group companies.

Assurance of employee reliability

The Republic of Lithuania Law on Prevention of Corruption (hereinafter referred to as the LPC) regulates that prior to the appointment of a person to a relevant position, it is obligatory to apply to the Special Investigation Service (hereinafter referred to as the STT) in order for the STT to collect and submit the information on the person as referred to in Article 16 of the LPC. Appointment to the position shall be subject to receipt and assessment of information from the STT.
The approved list of positions subject to mandatory referral to the STT is available here.
In accordance with the procedures set out in the LPC, the STT may also be contacted in respect of a person holding a position in the Company.

Assurance of National Security

Persons applying for certain positions in Ignitis Group companies (List of Positions Approved by Order of the Minister of Finance of the Republic of Lithuania of 11 September 2019 No. 1K-267) must be subject to a screening process in order to determine whether they meet the criteria set out in the Republic of Lithuania Law on the Protection of Objects of Importance to Ensuring National Security.

Appointments shall be subject to receipt and assessment of information received from the competent authorities.