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 and Conduct

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 operates in accordance with the highest ethical requirements and principles, following standards of openness and integrity. We strive to create a business culture for a responsible and sustainably developed energy sector.

We value transparent cooperation based on trust, partnership, and respect, and we believe that the best gift is sincere gratitude and attention. Within the Group, we adhere to the principle that we neither give nor accept Gifts, except for:

• Gifts in accordance with International Protocol ( International Protocol is understood as a set of rules and traditions established under customary law and universally recognised, which form the basis of interaction among governments, foreign services, diplomatic missions, official persons, and the like.) 
• Gifts during official and/or public events, when Gifts are given to an organisation during official and/or public events, to an Employee and/or their group, as representative(s) of the organization, in public view of other event participants (for example, a gift presented to the company on the occasion of Lithuanian Energy Workers' Day; a gift presented to the company for specific activities/ achievements/ results in a particular field.)

The Group seeks to ensure that appreciation for an Employee's good performance or successful cooperation is expressed not through Gifts, but through positive feedback or thanks.

All gifts received or presented are recorded in the Group's Gift Register.

Group Gift Standard

Trust line

Information in Estonian

Information in Latvian

Information in Polish

Information in Finnish

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 and Conduct, the Group's Anti-Corruption Policy, the Sustainability Policy, the Environmental Policy, the Policy of Equal Opportunities and Diversity, Supplier Code of Ethics

TRUST LINE CONTACT DETAILS

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. 

TRUST LINE CAN BE USED TO REPORT THE FOLLOWING VIOLATIONS IDENTIFIED WITHIN THE GROUP FOR:

• Corruption-related legal infringements;
• Violations of the Ignitis Group’s rules on the declaration of private interests;
• Serious violations of national and EU legal acts that cause harm to the public interest, finances, justice, or market transparency (whistleblower status may be granted when reporting such violations)*;
• Violations of the Ignitis Group’s Anti-Corruption Policy, Code of Ethics and Conduct, or Anti-Corruption Management System requirements;
• Violations of legal acts regulating public and commercial procurement;
• Improper performance or non-performance of employees' work duties;
• Violations of the Violence and Harassment Prevention Policy;
• Violations of legal acts regulating occupational health and safety;
• Other violations of legal acts and work duties.

Notifications are processed under the provisions of the Standard for the implementation and management of the Group's internal whistleblowing channels.

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

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.

Whistleblower protection

Information in Estonian

Information in Latvian

Information in Polish

Information in Finnish

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?

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) may also provide information Trust line.

WHERE TO REPORT VIOLATIONS? IGNITIS GROUP INTERNAL INFORMATION CHANNEL

A person can submit a violation report by:

• complete and submit by e-mail [email protected] a violation notification in the form prescribed by Law, or
• by e-mail [email protected] report a violation in free form, signed notice that it is submitted under the Whistleblower Protection Law.                                                                                                    

IMPORTANT. Your report will be forwarded to the General Prosecutor's Office, which will decide on your status as a whistleblower, in accordance with the Law. 

WHO IS RESPONSIBLE FOR EVALUATING AND FURTHER INVESTIGATING THE INFORMATION YOU PROVIDED?

The information provided in the reports is assessed by competent subjects appointed by the Group's Head of Business Resilience: 
Business Security Experts at Ignitis Group Service Centre UAB:

• Rimantas Avulis, [email protected] 
• Jevgenijus Bilis, [email protected]

Notifications are processed under the provisions of the Standard for the implementation and management of the Group's internal whistleblowing channels.

Assurance of confidentiality

All information provided to the Internal 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