Corporate Ethics

1.1. The purpose of the Corporate Ethics Regulations of the State Joint Stock company “Latvian State Radio and television Center” is to determine:

1.1.2. the conditions for combining positions or employment with another employer;

1.1.3. the provisions for giving and donating;

1.1.4. action to prevent conflict of interest;

1.1.5. how the possibility to report a possible violation in accordance with the whistleblowing Law is ensured;

1.1.6. the procedures by which whistleblower reports and submissions in relation to possible violations of ethical principles and norms of conduct shall be examined.

1.2. These Regulations shall be binding on all employees of the State Joint Stock company “Latvian State Radio and television Center”.

Connecting Positions

Performance of duties of the office of a State official in the State Joint Stock Company “Latvian State Radio and Television Center” concurrently with another position, enterprise agreement, authorisation, or economic activity as an individual merchant or registered economic activity performer, provided that no restrictions on combining positions are set by the Law on Prevention of Conflict of Interest in Activities of State Officials or other regulatory enactments.

Side Job

Work that an employee is entitled to perform for another employer. This means the employee may be simultaneously employed by multiple employers, unless prohibited by their employment contract. It also includes work performed by a public official that does not require special permission.

Employee

An employee of the State Joint Stock Company “Latvian State Radio and Television Center” or any other person engaged by the company under an employment contract or acting in its interests under an enterprise, authorisation, service, or other contract.

Gift

Any financial or non-financial benefit, including services, assignments, transfers, exemptions, waivers of rights, or any other activity resulting in a benefit, where the employee is the direct or indirect beneficiary.

Gift (Donation)

The transfer of funds, property, goods, or services owned by the State Joint Stock Company “Latvian State Radio and Television Center” free of charge to another person for a specified purpose.

Horizon HOP

The self-service portal for employees of the State Joint Stock Company “Latvian State Radio and Television Center”.

Submission

For the purposes of these Regulations, a submission reviewed by the Permanent Ethics Commission regarding possible breaches of ethical principles or rules of conduct, which is not recognised as a whistleblower report or a submission under the Law on Submissions.

Conflict of Interest

1) A situation in which a public official must make, participate in making, or influence a decision that affects or may affect the personal or financial interests of the official, their relatives, or business partners.
2) A situation in which an employee must make, initiate, participate in, or otherwise influence a decision affecting or potentially affecting the personal or financial interests of the employee, their relatives, or business partners.

Conflict of Interest Act

The Law “On Prevention of Conflict of Interest in Activities of Public Officials”.

INTRA

The Information Management System of the State Joint Stock Company “Latvian State Radio and Television Center”.

JD

The Legal Department.

Customer

A natural or legal person who has entered into an agreement with the State Joint Stock Company “Latvian State Radio and Television Center” for the provision of electronic communications services or who has initiated the process of entering into such an agreement.

Competent Authority

Any public institution responsible, in accordance with its legally defined competence, for addressing matters reported by a whistleblower, including higher authorities, supervisory or control institutions, investigative bodies, prosecutors, or sector-leading institutions.

LVRTC

The State Joint Stock Company “Latvian State Radio and Television Center”, registration No. 40003011203, Zemitana Street 9, k-3, Riga, Latvia, LV-1012.

Hate Speech

Public statements that spread, incite, justify, or encourage hatred or violence against individuals or groups identifiable by characteristics such as race, ethnicity, sex, age, sexual orientation, beliefs, or health status, with the intention of undermining human dignity and honour.

Namejs

The document management system of the State Joint Stock Company “Latvian State Radio and Television Center”.

Regulations

The Corporate Ethics Regulations of the State Joint Stock Company “Latvian State Radio and Television Center”.

PAD

The Human Resources Development Division.

Council

The Council of the State Joint Stock Company “Latvian State Radio and Television Center”.

Violation

Any criminal offence, administrative offence, breach of legal requirements, conduct contrary to the purpose of the law, or violation of binding ethical or professional standards.

Partner

A company, institution, or organisation that performs work or provides services to the State Joint Stock Company “Latvian State Radio and Television Center” under a contract.

Permanent Ethics Commission

A permanent commission of the State Joint Stock Company “Latvian State Radio and Television Center” responsible for reviewing whistleblower reports and submissions relating to possible breaches of ethics, conduct, or actions affecting the company’s activities or reputation.

Policy

The Corporate Ethics Policy of the State Joint Stock Company “Latvian State Radio and Television Center”.

Potential Employee

A person who has been offered employment with the State Joint Stock Company “Latvian State Radio and Television Center”.

Potential Conflict of Interest

A situation where a person's private interests, including financial, personal, or professional obligations, may in the future affect or risk affecting their objectivity, independence, or ability to act in the interests of the company.

Relative

A father, mother, grandmother, grandfather, child (including adopted child), grandchild, brother, sister, half-brother, half-sister, spouse, adoptive parent, or a partner officially registered in the Register of Natural Persons.

Register

For the purposes of these Regulations, the Register of Permits for Combining Positions and Performing Side Jobs.

Associated Person (within the meaning of the Whistleblowing Law)

A natural or legal person who supports or assists a whistleblower, whose involvement should remain confidential, and who could suffer adverse consequences due to their connection with the whistleblower.

Head of the Structural Unit

The manager to whom an employee is directly subordinate in the employment relationship (direct supervisor).

Perceived Conflict of Interest

A situation that creates doubts regarding an employee’s objectivity or impartiality in the performance of their duties.

Whistleblower

A natural person who reports information about a violation that may harm the public interest, genuinely believing the information to be true and having obtained it through work-related activities or legal relationships connected with work.

Whistleblower Report

A whistleblower report within the meaning of the Whistleblowing Law.

Management Board

The Management Board of the State Joint Stock Company “Latvian State Radio and Television Center”.

Public Official

Members of the Council, members of the Management Board, members of temporary procurement commissions, and other employees of the State Joint Stock Company “Latvian State Radio and Television Center” who perform functions defined by applicable legislation as constituting the status of a public official.

VEDUS

The Unified Electronic Work Task System of the State Joint Stock Company “Latvian State Radio and Television Center”.

Report

For the purposes of these Regulations, an application within the meaning of the Whistleblowing Law that has not been submitted as, and has not yet been recognised as, a whistleblower report.

3.1. In cases not regulated by the regulations, the employee shall act in accordance with the norms of corporate ethics policy, external regulatory enactments and general ethics and behavior.

3.2. The employee primarily deals with ethical issues with the head of his or her structural unit. The Ethics Trustee is a PAD manager who provides advice to employees on ethical issues, promoting common understanding and resolving uncertain situations.

3.3. For violations specified in these Regulations, an employee may be held disciplinary liable, an obligation to compensate losses may be imposed or the matter may be referred to another competent authority, including a law enforcement institution.

4.1. When interacting with colleagues and clients, the employee treats with respect for the rights and legitimate interests of each person. The employee is kind and polite, does not use offensive expressions, does not infringe on the honor of the person, is tolerant of the views and beliefs of others.

4.2. The employee is not arrogant and authoritarian in his relations with colleagues, listens to the opinion of others and evaluates it professionally.

4.3. The employee is responsive and cooperates with colleagues, providing and receiving the necessary support in the performance of professional duties, taking into account the competence of the employee in the specific issue and description of the position and does not abuse the trust of colleagues.

4.4. When taking decisions or participating in decision-making, expressing and justifiably defending the opinion expressed within the scope of his or her competence, the employee shall take into account the principles and guidelines defined in the Regulations.

4.5. The employee undertakes to:

4.5.1. to act outside the performance of official duties in such a way as not to discredit the LVRTC and its activities (position), as well as to avoid the publication of offensive, compromising, hateful recordings or materials (photographs, videos) on websites or social networks;

4.5.2. to observe applied etiquette and work culture, with correct behaviour, external appearance and actions that would promote justified public trust in LVRTC;

4.5.3. to resolve disagreements constructively in an atmosphere of mutual respect, openness, understanding and collegiality;

4.5.4. not to use unfamiliarity or mistakes in specific work matters of colleagues or other persons for malicious purposes, but to correctly indicate them, improvement thereof in accordance with the requirements specified in the job description of the colleague;

4.5.5. be able to acknowledge and correct his or her mistakes and improper actions in the performance of work and relations with other colleagues or clients;

4.5.6 to inform colleagues about professionally relevant topics and experiences that may be useful to other employees. Employees are prohibited from using psychological manipulative methods in their relationships, such as mobbing (when one or several colleagues systematically target one of their colleagues in a hostile and unethical way) or bossing (when a representative of the employer's management implements psychological terror).

4.6. Employees performing the duties of the head of the LVRTC, in addition to the duties of the employee specified in this Chapter:

4.6.1. always act in accordance with the requirements which they themselves impose on subordinates;

4.6.2. promote employees' understanding of the LVRTC mission, mobilize them for the benefit of common interests and promote mutual trust;

4.6.3. create a work environment based on openness, participation, professionalism and respectful and equal treatment;

4.6.4. promote the involvement of employees in the development of the LVRTC, promote their professional development and initiative, interest in the performance of duties and performance improvement;

4.6.5. promote the continuity of professional knowledge, introduction of new employees into work and their development;

4.6.6 criticism of an employee's work shall be expressed individually, substantiating it. Stresses the importance of cooperation in achieving common goals by expressing positive appreciation for teamwork;

4.6.7. regularly evaluate its own and employees' activities, employee involvement and customer satisfaction in order to constantly improve the work of LVRTC.

5.1. Deliberate concealment or misrepresentation of information – in any form.

5.2. Corruption, bribery or gifts with hidden intent, including in relation to a foreign official, shall not be allowed to influence in any way.

5.3. Discrimination, violence (physical or emotional) – against every person.

5.4. Leakage of company data or deliberate breach of security – even in cases where there is no direct malicious intent.

5.5. Concealing a conflict of interest, whether the decision is affected or not.

6.1. An employee who performs the duties of a public official has a duty to ensure that the combination of positions does not cause a conflict of interest, a violation of ethical norms or interfere with the performance of LVRTC's direct official duties. An employee may not perform the duties of the position if his work with another employer raises suspicions of a conflict of interest, including a potential conflict of interest or a perceived conflict of interest that interferes with the performance of the tasks and functions specified by the LVRTC.

6.2. The employee has a duty to ensure that the performance of side job does not create undesirable competition, violation of ethical norms, doubts about the employee's loyalty, does not interfere with the performance of direct work duties in accordance with the provisions of the employment contract and regulatory enactments, as well as the relevant side job does not harm the reputation of LVRTC.

6.3. The employee shall be responsible for compliance with the requirements specified in the Regulations for the performance of side job. An employee who is a public official shall be responsible for compliance with the requirements specified in the Regulations and the conflict of interest Law for combining positions or performing side job and earning income.

6.4. The employee has a duty to co-ordinate the performance of side job in accordance with the procedures and within the time period specified in the Regulations. An employee who is a public official has a duty to co-ordinate the combination of positions in accordance with the procedures and within the time period specified in the Conflict of interest Law and Regulations. If the work performed by an employee who is a public official outside the LVRTC does not fall within the category of positions specified in the Conflict of interest Law, the connection of which must be coordinated, then the performance of this work performed outside the LVRTC must be coordinated as the performance of side job in accordance with the procedures and within the time period specified in the regulations.

6.5. For non-compliance with the duties specified in this Chapter, an employee who is not a public official may be subject to disciplinary liability, but an employee who is a public official may be subject to administrative or disciplinary liability.

6.6. The alignment of positions or the performance of side job shall take place in accordance with the description of the sub-process “Alignment of positions and side job” of the process “Personnel Management”.

6.7. An employee creates an application to connect positions or do side job at Horizon hop. The application shall indicate the information indicated in the Horizon hop application form, as well as the time period for which the authorisation to combine positions or perform side job is requested. This period may not exceed two years from the date of submission of the application.

6.8. An employee who has been subordinated to the Council shall submit an application to the Council, sending it by e-mail, next to the receipt of the work performance or co-ordination of the position within the time periods specified in Clause 6.10 or 6.11. The Council shall examine the relevant application in accordance with the procedures specified in regulatory enactments as the Council takes decisions. An employee who has been subordinated to the Council shall submit the decision taken by the Council regarding co-ordination or refusal to co-ordinate the performance of job combinations or side job to the PAD, which shall enter information regarding the decision taken in the Register.

6.9. The PAD shall ensure that a potential employee submits an application to the LVRTC for the co-ordination of job combinations and organises the referral of such application for co-ordination with the managers indicated in Clause 6.13. The PAD shall inform the potential employee regarding the decision taken and, if the employee enters into an employment contract, enter information regarding the decision taken in the register.

6.10. An employee shall submit an application for co-ordination of side job to Horizon hop not later than: 6.10.1. two weeks before the commencement of side job, as well as within such time period, submit an application for repeated co-ordination of side job, if the time period for co-ordination of side job expires and it is planned to continue side job;

6.10.2. within seven days from the commencement of the performance of work duties at the LVRTC, if the employee is already performing side job.

6.11. If the combination of offices of a public official in accordance with the Conflict of interest Law is permissible, an employee shall submit an application for the coordination of positions of an official to Horizon HOP not later than within seven days before the determination of the status of a public official or before the commencement of the performance of another office outside the LVRTC, if he or she already performs the duties of the office of a public official. If the issued permit for combining positions expires and it is planned to continue combining positions, the employee who performs the duties of a public official shall submit a new application for combining positions not later than seven days before the expiry of the term of the previous permit.

6.12. An employee shall receive permission to combine positions or perform side job for each position or side job to be performed separately.

6.13. The combination of each post or the performance of each side job must be coordinated:

6.13.1. employees who work in units subordinated to the Director of the Department - with the head of their unit and the Director of the Department;

6.13.2. employees who work in structural units subordinated to a member of the management board - with the head of their structural unit and the responsible member of the management board;

6.13.3. heads of the unit subordinated to the Director of the Department - with the Director of the Department and the responsible member of the management Board;

6.13.4. heads of structural units subordinate to the member of the management board and directors of departments with the responsible member of the management board;

6.13.5. for employees subordinated to the Council - with the Council.

6.14. If the manager referred to in Sub-paragraphs 6.13.1 - 6.13.4 of the employee determines that the combining of positions does not cause a conflict of interest, violation of ethical norms and does not interfere with the fulfilment of direct duties of the position, he or she shall co-ordinate the application for combining the positions of the employee with Horizon HOP. If the manager referred to in Sub-paragraphs 6.13.1 - 6.13.4 of the employee determines that the performance of side job does not cause undesirable competition, violation of ethical norms, doubts regarding the employee's loyalty, does not interfere with the performance of direct work duties at LVRTC in accordance with the provisions of the employment contract and regulatory enactments or the relevant side job does not harm the reputation of LVRTC, he or she shall co-ordinate the employee's application for the performance of side job at Horizon HOP. The decision to issue the permit shall be taken by the Supreme Leader or the Council referred to in Sub-paragraphs 6.13.1 to 6.13.4 in the case referred to in Sub-paragraph 6.13.5.

6.15. If the manager referred to in Sub-paragraphs 6.13.1 to 6.13.4 of the employee establishes at least one circumstance referred to in Sub-paragraph 6.14 that prevents co-ordination of positions or side job, he or she shall urgently inform thereof another manager involved in the examination of the particular application and an internal control and compliance expert, specifying in detail in writing the reasons why a permit for combining positions or performing side job may not be issued. A draft decision regarding refusal to issue a permit for combining the position or performing side job shall be prepared by the manager referred to in Sub-paragraphs 6.13.1 to 6.13.4 of the employee, who does not co-ordinate combining the position of the employee or performing side job, in co-operation with an internal control and compliance expert and another manager involved in the examination of the relevant application.

6.16. A decision to refuse to issue a permit for combining positions or performing side job shall be taken by the supreme manager or council referred to in Sub-paragraphs 6.13.1 to 6.13.4 in the case referred to in Sub-paragraph 6.13.5. A decision to refuse to issue a permit for combining a position shall be taken in accordance with the procedures and within the time period specified in the Administrative Procedure Law. The prepared decision on refusal to issue a permit for combining positions or performing side job shall be co-ordinated, signed and sent to the employee or potential employee in Namejs, except in the case referred to in Sub-paragraph 6.13.5. In the conciliation comment of Horizon HOP application for a job combination permit or side job, it shall be entered that the job combination or side job performance has not been coordinated in accordance with the decision registered in Namejs, indicating the date and number of registration of this decision.

6.17. If an employee's application for combining positions or performing side job is rejected because the information necessary for the issuance of a permit has not been submitted, such rejection shall not be considered as a decision referred to in Clause 6.16 regarding refusal to issue a permit for combining positions or performing side job.

6.18. If an employee has a valid permit for combining positions or performing side job, but the manager referred to in Sub-paragraphs 6.13.1 to 6.13.4 determines at least one criterion referred to in Sub-paragraph 6.14, which would prevent the issue of the relevant permit, then, by involving an internal control and compliance expert, such manager shall prepare a decision in Namejs regarding the revocation of the relevant permit in accordance with the procedures specified in Sub-paragraph 6.16 and inform the PAD thereof in addition. The PAD shall make the necessary changes to the register.

6.19. If it is determined that an employee joins positions or performs side job without co-ordination, the head of the PAD shall be informed thereof, who shall contact the particular employee and the head of his or her structural unit in order to resolve the situation.

6.20. Authorisation to combine posts or carry out side job shall be issued for a period of two years from the date of submission of the application, unless a shorter time period is specified in the application. If the application does not specify the time period for combining positions or performing side job, the permit shall be deemed to have been issued for a period of two years from the date of submission of the application. Permits for combining positions or performing side job issued until the coming into force of the version of these Regulations, irrespective of the specified time period, shall be valid for two years from the date of submission of the application. If the permit has been issued for an application in which the term of the permit has not been indicated or the application has been applied for as open-ended, then the permit issued until the coming into force of the version of this Regulation shall be valid for one year from the day of submission of the application, but if the period of one year has already passed, then it shall be valid for one month from the day of coming into force of the version of this Regulation.

6.21. If after the termination of the time period for combining positions or performing side job the employee wishes to continue combining positions or performing side job, he or she shall submit a new application for combining positions or performing side job within the time period referred to in paragraphs 6.10 and 6.11 of these Regulations.

6.22. It is the employee's responsibility to keep track of the permit's expiration date.

6.23. If new circumstances arise for the employee during the job combination or side job that may affect the previously performed coordination, including changes in the employee's position or structural unit, the employee immediately creates a new job combination or side job coordination application in Horizon HOP, indicating in addition to the information to be indicated that the existing permit is in force, but the aforementioned circumstances have occurred and indicate them. The employee referred to in Sub-paragraph 6.13.5 of these Regulations shall submit a new application to the Council in such a situation, indicating that the existing permit is in effect, but circumstances have arisen which may affect the previously performed co-ordination and indicate them. The examination of such applications and submissions shall take place in accordance with the procedures specified in the Regulations.

6.24. An employee who already works at LVRTC and wishes to perform side job may commence the performance of side job only after obtaining a permit for the performance of side job. If an employee is not issued a permit for the performance of side job, which he or she is already performing, or a decision granting a permit for the performance of side job is revoked, the employee must evaluate the possibility of stopping the performance of side job within one month and notify the head of the structural unit of the termination of side job. If the employee refuses to stop the performance of side job, the direct supervisor shall inform the PAD thereof and the further performance of the employee's work duties shall be resolved by the LVRTC in accordance with the procedures specified in the regulations, other internal regulatory enactments and the Labour Law.

6.25. If the employee is not coordinated with the position combination or the decision to issue a permit for the position combination is revoked, the employee and the LVRTC must act in accordance with the provisions of the Conflict of interest Law.

6.26. If an employee who performs the duties of a public official simultaneously holds a position, the combination of which with the position of a public official is prohibited, the employee shall act in accordance with the procedures specified in the Conflict of interest Law.

6.27. For the purposes of combining the positions of an employee or performing an assessment of an application for co-ordination of a side job, the co-ordinators of the position referred to in Paragraph 6.14 of the Regulations, but also the internal control and compliance expert for the purposes of preparing the decision referred to in Paragraph 6.15, are entitled to request and receive information from other LVRTC structural units and databases.

6.28. The register is maintained by PAD Horizon. 6.29. The PAD shall provide information from the Register to other structural units regarding the side job of a particular employee or the combination of positions, observing the conditions for the protection of personal data, and shall provide information only in such content and to the extent that such information is necessary for the detection and/or elimination of the circumstances referred to in Paragraph 6.14 of the Regulation. An internal control and compliance expert shall be granted access to the register for the performance of his or her duties. 6.30. The internal control and compliance expert shall perform control not less than once every two years regarding the conformity of the co-ordination of co-work and job combinations declared by officials and employees with the information at the disposal of the LVRTC in the register with publicly available information. The internal control and compliance expert shall submit the facts established in the control to the head of the PAD, who in case of non-conformities (discrepancies) shall contact the specific employee and the head of his or her unit for the solution of the situation.

7.1. If an employee, including a public official, has to take a decision or perform other activities related to the official duty, which affect or may affect the personal or financial interests of the employee himself, his relatives or counterparties, or the objectivity and neutrality of the employee's activities may be questioned for ethical reasons, then the employee shall refuse to take such a decision or perform the official activity and shall act in accordance with the procedures specified in Clause 7.2.

7.2. The employee is obliged to immediately inform the Management Board, the head of his or her structural unit and the Chairman of the Procurement Commission (if a conflict of interest situation arises in the procurement), as well as the internal control and compliance expert about the conflict of interest, including a perceived conflict of interest or potential conflict of interest, as well as in the case referred to in Clause 7.1 by sending an e-mail with an outline of the situation.

7.3. The head of the structural unit shall immediately, but not longer than within three working days from receipt of the e-mail referred to in Clause 7.2, evaluate the information referred to in this e-mail and, if a conflict of interest is recognised, take an appropriate decision to resolve the situation:

7.3.1. means another employee for taking a decision or performing the relevant activities;

7.3.2. inform the Management Board if a decision of the Management Board is necessary for the performance of the action;

7.3.3. take another decision appropriate for solving the situation.

7.4. The Chair of the Procurement Commission shall immediately, but not later than within three working days from receipt of the e-mail referred to in Clause 7.2, convene a meeting of the Procurement Commission for evaluation of the information referred to in this e-mail and taking a decision on further action to resolve the situation. If the Procurement Commission establishes a conflict of interest, the Chairperson of the Procurement Commission shall:

7.4.1. apply to the head of the unit to delegate another employee to work in the Commission, if necessary;

7.4.2. inform the responsible employee regarding the necessity to make changes to the order determining the composition of the relevant procurement Commission;

7.4.3. apply to the Procurement Commission for taking a decision (if applicable).

7.5. The head of the structural unit and the Chairman of the Procurement Commission shall generally inform the internal control and compliance expert in an e-mail regarding the actions taken and decisions taken to prevent a conflict of interest situation.

8.1. According to the Whistleblowing Law, LVRTC has established an internal whistleblowing system.

8.2. A whistleblower is entitled to raise the alarm regarding possible, occurred or ongoing violations, which have been established in the performance of work duties, which are not individual in nature and which are brought for the benefit of the company or any part thereof, as well as regarding attempts to conceal such violations, especially violations in the following areas:

8.2.1. inaction, negligence, abuse of official position or other illegal activity of officials;

8.2.2. corruption, as well as violations of the financing regulations of political organisations (parties) and associations thereof and restrictions on pre-election campaigning;

8.2.3. waste of financial resources or property of a public person;

8.2.4. tax evasion;

8.2.5. threat to public health;

8.2.6. threat to food safety;

8.2.7. threat to construction safety;

8.2.8. threats to environmental safety, including actions affecting climate change;

8.2.9. radiation protection and nuclear safety;

8.2.10. occupational safety hazards;

8.2.11. threat to public order;

8.2.12. human rights violations;

8.2.13. violations in the field of public procurement and public-private partnership;

8.2.14. violations in the financial and capital market sector;

8.2.15. money laundering and prevention of terrorism and proliferation financing;

8.2.16. violations of competition law and commercial activity support regulations;

8.2.17. violations in the field of provision of goods and services, including in relation to safety and compliance;

8.2.18. violations in transport safety;

8.2.19. infringements in relation to the internal market, as referred to in Article 26(2) of the Treaty on the Functioning of the European Union, including infringements of the competition and State aid rules of the European Union, as well as infringements in relation to the internal market in relation to activities, which are in contradiction with the provisions regarding corporate income tax, or mechanisms, the purpose of which is to obtain tax advantages by addressing the objective of the applicable Corporate income tax law;

8.2.20. violations in the field of animal welfare;

8.2.21. consumer rights protection;

8.2.22. protection of privacy and personal data and security of network and information systems;

8.2.2. hate speech;

8.2.24 fraud, including fraud and any other illegal activity affecting the financial interests of the European Union, as referred to in Article 325 of the Treaty on the Functioning of the European Union and further specified in the relevant measures of the European Union.

8.3. If information comes to the person's attention or if he or she has witnessed any of the violations referred to in Clause 8.2 or if another employee acts contrary to external regulatory enactments or internal regulatory enactments of the LVRTC, as well as if the violation can be effectively responded to internally by the LVRTC and the person believes that it will not have adverse consequences, the person has a duty to report it to the permanent Ethics Commission as a priority.

8.4. If the whistleblower has reason to believe that by reporting internally to the LVRTC he or she may endanger himself or for any other reason report internally is ineffective, then the whistleblower's report on the violations referred to in Clause 8.2 may be submitted to:

8.4.1. by contacting the competent authority (the list is available on www.trauksmescelejs.lv);

8.4.2. using a whistleblower at the contact point of the Corruption Prevention and Combating Bureau (contacts are available on www.trauksmescelejs.lv) or through an association or foundation (including a trade union or trade union association).

8.5. The whistleblower report may be submitted in writing, in paper form, electronically or orally.

8.6. In writing the whistleblower report:

8.6.1. may be prepared in free form, indicating the information referred to in Section 6, paragraphs one, two, three and four of the Law on whistleblowing, including clearly stating that it is a whistleblower report;

8.6.2. may be prepared using the whistleblower report form (Annex 1 to this Regulation, which is also available in the LVRTC information management system INTRA in the section “Internal whistleblowing system”);

8.6.3. by filling in the form of the online whistleblower report on www.trauksmescelejs.lv website.

8.7. The whistleblower's report must be signed by hand, submitted electronically - must be signed with a secure electronic signature. A whistleblower report may also be submitted electronically without a secure electronic signature on the State Administration Services Portal www.latvija.gov.lv or on the website www.trauksmescelejs.lv, if the report is submitted and the identity of the person is verified using online forms available on the portal and website.

8.8. The whistleblower's report in paper form can be sent by post to the registered office of the LVRTC (Zemitana Street 9 – k 3, Riga), placing it in a closed envelope and clearly stating in the report that it is the whistleblower's report, or by submitting it to the Office administrator and or the head of the PAD, availability - 8/5. 8.9. The whistleblower's report can be submitted electronically by sending LVRTC to the e-mail address , sending to the e-address of LVRTC or another competent institution on the portal www.latvija.gov.lv, via the portal www.trauksmescelejs.lv LVRTC (will be received by e-mail ) or another competent institution, availability - 24/7.

8.10. An oral whistleblower report may be expressed to the Office Administrator or the head of the PAD by contacting the official phone number of the LVRTC 67108787 or by calling directly the Office Administrator or the head of the PAD or by other means of messaging, as well as by meeting in person (availability - 8/5) within a reasonable time at the request of the employee. An oral whistleblower report shall be drawn up taking into account the provisions laid down in Section 6, Paragraph 1.1 of the Law on Whistleblowing.

8.11. Whistleblowing contact person LVRTC is an internal control and compliance expert who also provides consultations to employees, and about whom the corruption Prevention and Combating Bureau has been informed.

8.12. An alarm may also be raised by providing information in public if at least one of the following conditions is met:

8.12.1. within 2 months from the recognition of the submission as a whistleblower report, the whistleblower shall not be informed regarding the progress of the examination of his or her whistleblower report;

8.12.2. the violation indicated in the whistleblower report is not rectified for a long time without objective reason;

8.12.3. the person has reason to believe that the violation may be an imminent or clear threat to the public interest, including in the case of an emergency situation or a risk of imminent harm;

8.12.4 a person has reason to believe that contacting the competent authority will lead to adverse consequences or prevent the violation, including the institution itself being involved in the violation or concealing or destroying evidence or entering into prohibited agreements.

8.13. Knowingly providing false information, disclosing information containing state secrets, reporting only for violation of personal interests shall not be considered whistleblowing.

8.14. Anonymous reports regarding violations referred to in Clause 8.2 shall be examined in accordance with the procedures laid down in the Law on Submisions.

8.15. The LVRTC shall provide the following guarantees of protection to the whistleblower, his or her relatives and associated person from the moment when the whistleblower has raised the alarm:

8.15.1. identity protection;

8.15.2. protection against adverse consequences caused by whistleblowing, including against the following actions by LVRTC:

8.15.2.1. to impose disciplinary or other punishment;

8.15.2.2. to be dismissed from work or office, including without extending the employment contract or appointing him or her to office for an indefinite period of time, if there were grounds to believe that this would be done;

8.15.2.3. transfer to another job or position;

8.15.2.4. to deny promotion, training or improvement of qualification;

8.15.2.5. to change the duties, working hours and place of work or remuneration of work or office;

8.15.2.6. to provide a negative assessment of work and duties;

8.15.2.7. to violate honour, dignity and reputation;

8.15.2.8. to cancel licences and permits;

8.15.2.9. unilaterally withdraw from or terminate the contract regarding the supply of goods, purchase or provision of services;

8.15.2.10. to request the opinion of a doctor;

8.15.2.11. otherwise directly or indirectly cause adverse consequences, including in violation of the principle of equal treatment;

8.15.2.12. to influence, intimidate, harass or ostracise;

8.15.2.13. to cause losses;

8.15.2.14. to be included in the list on the basis of formal or informal information at the level of the sector or sector, thereby hindering or preventing further activities in the sector or sector;

8.15.2.15 to make a false application to the court.

8.16. The whistleblower, his relatives and associated persons are also entitled to other nationwide safeguards with the moment the whistleblower raised the alarm (advice available on www.trauksmescelejs.lv).

9.1. The activities, structure, functions and tasks of the permanent Ethics Commission are determined by the rules for the management of the organizational structure of the LVRTC.

9.2. Principles of the permanent Ethics Commission:

9.2.1. integrity - in its activities the standing Ethics Commission shall be accurate, honest, plan and anticipate the results of its activities;

9.2.2. neutrality - the permanent Ethics Commission shall maintain a neutral position during the course of operation and at the moment when the decision is taken;

9.2.3. favour – the standing Ethics Commission shall hear the persons involved in the case or examination of the matter in a favourable and encouraging atmosphere;

9.2.4. impartiality - the standing Ethics Commission shall examine submissions or whistleblower reports objectively and impartially, observing equality of all persons before the law and without showing special favour or privileges to any particular person involved in the examination matter;

9.2.5. responsibility and argumentation - the permanent Ethics Commission shall perform only reasoned activities, shall be responsible for the process of its activities and the results thereof;

9.2.6. independence - the permanent Ethics Commission shall be independent in its activities and decision-making, in the provision of opinions;

9.2.7. confidentiality – during the examination of a submission or whistleblower's report, confidentiality is preserved and the requirements for the protection of personal data are observed. Members of the permanent Ethics Commission are prohibited from disclosing information obtained while serving on the Commission, except as required by law.

10.1. The permanent Ethics Commission shall have the following rights:.

10.1.1. within the scope of its competence, request and receive information and explanations from employees, observing the procedures for the circulation of documents specified by the LVRTC;

10.1.2. to invite the employees indicated in the submission or whistleblower report and other employees involved in the opinion of the permanent Ethics Commission to the meetings of the permanent Ethics Commission for the provision of explanations;

10.1.3. to take a decision or provide an opinion in accordance with the procedures specified in the Regulations and other internal and external regulatory enactments.

10.2. The chairperson of the permanent Ethics Commission is entitled to sign requests for explanations of the permanent Ethics Commission, requests for information, correspondence to be sent to the submitter of the application regarding ethical violations or the whistleblower, to forward the whistleblower's report to the competent authority.

10.3. The permanent Ethics Commission shall be responsible for:

10.3.1. The performance of the tasks specified in the governance regulations of the organisational structure, these regulations and other internal and external regulatory enactments;

10.3.2. compliance of its decisions with the management regulations of the organisational structure, these regulations, requirements of other external and internal regulatory enactments.

10.4. Any member of the permanent Ethics Commission may be recalled from the composition of the permanent Ethics Commission by order of the Management Board or may himself or herself refuse to perform the duties of Chairman or Member of the permanent Ethics Commission by submitting an application to the Management Board.

11.1. The Office administrator shall register in Namejs submissions or a whistleblower report, the examination of which falls within the competence of the permanent Ethics Commission, as restricted access information in accordance with the process “correspondence Management”, ensuring access only to the members of the permanent Ethics Commission. Whistleblower reports shall be separated from other documentation and assigned a separate identifier.

11.2. The submission or pseudonymized whistleblower report shall be directed to the Chairman of the permanent Ethics Commission for consideration by the Office Administrator in Namejs.

11.3. If the information included in the employee's application or whistleblower's report is related to a member or chairperson of the permanent Ethics Commission, the Office administrator shall ensure that the application or whistleblower's report is not diverted to the referred to member or chairperson of the permanent Ethics Commission. The Office administrator shall inform the chairperson of the permanent Ethics Commission (if the submission or whistleblower's report has not been submitted regarding him or her) and the chairperson of the management board or a member of the management board authorised to sign the order documents in the absence of the chairperson of the management board regarding such report or submission of the whistleblower. The Chairperson of the Management Board or the Chairperson of the Board, P.I., shall decide on the appointment of another member or Chairperson of the permanent Ethics Commission to serve on this Commission until the circumstances preventing it have ceased. Conflict of interest situation shall be resolved in accordance with internal and external regulatory enactments regarding prevention of conflict of interest situation.

11.4. Members of the permanent Ethics Commission, the Office administrator, its substitute or employee who has access to information related to the examination of submissions or whistleblower reports for the performance of work duties (for example, the system administrator), shall be prohibited from disclosing information that reveals the identity of the natural or legal person reported by the submitter or whistleblower, as well as information regarding the submitter, whistleblower and associated person himself or herself. The referred to information may be provided only to a person or institution for which it is necessary for the examination of a whistleblower report or an infringement case initiated on the basis thereof or for the protection of the whistleblower, his or her relative or associated person, as well as if it is provided for in an external regulatory enactment.

11.5. Before examining an application or whistleblower report, the members of the permanent Ethics Commission shall certify in accordance with regulatory enactments that they are not interested in examining the application or whistleblower report (personally, according to the procedure of subordination of positions) or shall immediately notify the chairperson of the permanent Ethics Commission or his or her substitute regarding circumstances that prevent the certification of disinterest.

11.6. All persons (not only members of the permanent Ethics Commission) who are involved in the examination and verification of a submission or whistleblower report shall comply with the requirements regarding both neutrality and confidentiality, protection of the whistleblower and his relatives or associated persons, protection of personal data and other requirements in accordance with these Regulations and other regulatory enactments.

11.7. The report of a whistleblower shall be examined by the permanent Ethics Commission in accordance with the procedures laid down in Annex 2 to the Regulations, procedures for examination of the report of a whistleblower.

11.8. The permanent Ethics Commission shall examine submissions related to violations of ethical principles and norms of conduct in accordance with the procedures specified in Annex 3 to the Regulations, Special procedures for examination of submissions regarding possible violations of ethical principles and norms of conduct.

11.9. The chairperson of the permanent Ethics Commission shall determine the time period of the meeting of the permanent Ethics Commission within three working days after receipt of the submission or whistleblower report, notifying the members of the permanent Ethics Commission thereof.

11.10. Meetings of the permanent Ethics Commission shall be held in person, remotely or in a hybrid mode. Meetings of the Commission shall be convened by the chairperson of the Commission.

11.11. Minutes of the meeting of the permanent Ethics Commission shall be taken by the member appointed by the chairperson of the permanent Ethics Commission. The minutes shall indicate:

11.11.1. The venue and time of the meeting of the permanent Ethics Commission;

11.11.2. Participants in the meeting of the permanent Ethics Commission;

11.11.3. the course and content of the discussion of issues;

11.11.4. the procedural decisions taken and the vote.

11.12. The minutes of the meeting of the permanent Ethics Commission shall be prepared within three working days after the day of the meeting of the permanent Ethics Commission.

11.13. The permanent Ethics Commission shall record the result of examination of the submission or whistleblower report in the opinion.

11.14. The opinion of the permanent Ethics Commission, when examining an application regarding a possible violation of ethical or behavioral norms, shall be of a recommendatory nature to the employee regarding whose actions the application has been submitted or to the employee who has submitted the application, the head of the employee's structural unit or the board. The opinion of the permanent Ethics Commission in considering the whistleblower report shall be of a recommendatory nature to the Management Board.

11.15. The opinion may include a recommendation on:

11.15.1. Holding an employee liable for disciplinary action if the permanent Ethics Commission sees signs of discipline violation in the employee's actions;

11.15.2. implementation of corrective actions and/or additional control mechanisms in the operation of the LVRTC;

11.15.3. any other recommendations to the LVRTC, its employees or the Management Board.

11.16. The permanent Ethics Commission shall submit an opinion regarding the outcome of the examination of a whistleblower's report or submission regarding a possible violation of ethical principles or norms of conduct for examination at a meeting of the Management Board within three working days after the adoption of the opinion. A decision regarding examination of a whistleblower report or examination of a submission regarding a possible violation of ethical principles or norms of conduct shall be taken by the Management Board. The Management Board, when considering the opinion, shall decide on the implementation of the proposals made by the permanent Ethics Commission and on the determination of the deadlines for the implementation of the persons and actions responsible for their implementation, if the proposal is supported. The Management Board may take a different decision from the proposals of the permanent Ethics Commission, which is aimed at resolving the relevant situation indicated in the opinion. If there is a conflict of interest to the extent that only one member of the Management Board may examine the matter, the permanent Ethics Commission shall submit the opinion to the Council for consideration.

11.17. The opinion of the permanent Ethics Commission shall be signed by all members of the permanent Ethics Commission who participate in the preparation of the opinion.

12.1. Within five working days from the day when the employee becomes a permanent State official or ceases to perform the duties of a permanent State official, including if the employee is not a State official but starts to replace and ceases to replace the State official, the responsible employee of the Accounting Department Horizon HOP shall be informed thereof.

12.2. In the procurement order the preparer shall indicate the employees who will perform duties in the relevant procurement Commission. The originator of the relevant order shall ensure familiarisation of the responsible employee of the Accounting Department with this order.

12.3. A member of the Procurement Commission shall, within five working days after entering into a procurement contract or termination or termination of a procurement, inform the responsible employee of the Accounting Department regarding exclusion of himself or herself from the list of a State official by sending information to the e-mail , except if the specific person continues to fulfil the duties of a State official in the LVRTC as a permanent State official or in any other procurement Commission, including if a procurement regarding the relevant procurement object is repeatedly organised and the member of the Procurement Commission continues to fulfil the duties of a member of the Procurement Commission.

12.4. The head of the Accounting Department shall ensure that the list of State officials of the LVRTC and amendments thereto are sent to the State Revenue Service in accordance with the procedures and within the time period specified in the Conflict of interest Law and Cabinet regulations issued on the basis thereof, providing information regarding both permanent State officials and State officials for the time period while they perform their duties in the Procurement Commission.

12.5. The Internal control and compliance expert shall, at least once every three years, together with the heads of structural units, reassess the functions and positions exposed to the corruption risks of the LVRTC. In the interim, an internal control and compliance expert shall perform an assessment of new positions in relation to corruption, conflict of interest and fraud risks in accordance with the procedures and within the time period specified in the governance regulations of the organisational structure.

12.6. The identification, assessment, determination and control of corruption risks of the LVRTC shall be performed in accordance with the procedures specified in the risk Management Regulations.

12.7. Each year, the internal control and compliance expert publishes information on the implementation of the previous year's anti-corruption measure plan on the LVRTC website, but not later than three months after the approval of the annual report.

12.8. The anti-corruption action plan shall be reviewed and, if necessary, amended once a year.

12.9. The anti-corruption plan may also be revised and amended in the event of exceptional circumstances such as conflict of interest and corruption.

12.10. LVRTC shall immediately inform the competent authority regarding conflict of interest and corrupt violations committed by State officials (Corruption Prevention and Combating Bureau, State Revenue Service or the Constitution Protection Bureau, other competent authority).

13.1. LVRTC does not accept donations (gifts).

13.2. Donations from LVRTC shall be made in the cases specified in internal and external regulatory enactments and in accordance with the procedures specified. LVRTC may donate (gift) if the conditions specified in the corruption and conflict of interest risk prevention are ensured and all the conditions specified in the donation (gift) performance, which are specified in the corruption and conflict of interest risk prevention policy and Annex 4 to the Regulations, are fulfilled.

13.3. The LVRTC Management Board may take a separate decision to make donations also in cases where all the conditions specified for making a donation (donation), as specified in Annex 4 to the Regulations, are not fulfilled, insofar as it is in accordance with the requirements of regulatory enactments and the special legal framework in force at that time.

14.1. It is JD's responsibility to manage the rules.

14.2. Amendments are made to the Regulations due to changes in the regulatory enactments of the Republic of Latvia, as well as by improving the quality management or internal control system of the LVRTC. The procedures for submission and examination of whistleblower reports specified in the Regulations shall be reviewed not less than once every three years.

14.3. These Regulations shall come into force after their approval at the meeting of the Management Board of LVRTC in accordance with the procedures specified in the decision of the Management Board.

14.4. The current version of the rules is maintained in Namejs.