Anti-corruption and prevention of conflicts of interest

- Reassessment of LVRTC positions and functions in relation to corruption and conflict of interest risks was conducted. Positions and functions with elevated risks were identified, and measures were defined to mitigate these risks.

- Internal employee training was organized on corporate ethics rules, covering topics such as corruption, conflicts of interest, dual employment, whistleblowing, and corporate ethics.

Regular user access rights reviews were conducted in LVRTC information systems. An inventory of all Active Directory accounts was performed. Account parameters were reviewed to proactively prevent potential information security risks.

The annual information systems security briefing and assessment test were developed and updated. LVRTC employees reviewed the briefing and completed the test to verify their knowledge.

Internal phishing campaign simulations were carried out.

Information security training was provided to internal Trusted Service Provider (hereinafter – TSP) employees and external TSP partners.

IT security onboarding briefings were conducted for new LVRTC employees.

- A control audit was conducted to ensure that the declared secondary employment and dual positions of public officials and employees were in compliance with internal regulations.

- The possibility of joining the NGO “Sabiedrība par atklātību – Delna” initiative "Zero Tolerance for Corruption".

- A priority audit was conducted on whistleblowing, conflict of interest, and anti-corruption prevention systems. Internal audit assessment: the internal control systems related to anti-corruption, conflict of interest, and whistleblowing are operational, although certain improvements are needed (overall assessed as sufficiently effective).

- Risks of corruption and conflicts of interest were reassessed, and an anti-corruption action plan for 2024 was approved.

- A priority audit was conducted on procurement procedures. Internal audit assessment: internal control systems in the area of procurement (within the audit scope) are functioning, though some improvements are needed (sufficiently effective).

- To ensure lawful, timely, effective, economically justified, and appropriate use of financial resources in line with LVRTC’s needs and in accordance with regulatory requirements for public procurement, new internal regulations were approved — Regulations on Procurement Planning and Organization. These consolidate and update three previous LVRTC internal regulatory acts: the Procurement Committee Regulations, the Procurement Planning and Organization Regulations, and the Exception Procurement Regulations, incorporating both amendments and new legal provisions.

- Employees were briefed on conflict-of-interest issues in the procurement process.

- A priority audit was conducted on the anti-corruption, conflict of interest prevention, and whistleblowing systems. Internal audit assessment: the internal control systems are functioning, though some improvements are needed (sufficiently effective).

- The Corporate Ethics Regulations were updated to reflect current issues related to ethics, corruption, conflict of interest, and whistleblowing.

- Internal training was provided to employees, including new hires, on the core principles of the Corporate Ethics Regulations, including whistleblowing.

-Intranet information was updated to make materials on corruption prevention, conflicts of interest, and whistleblowing easily accessible and understandable for all employees, including visual and explanatory content.

- A calendar matrix was created on the intranet to indicate deadlines and frequencies for carrying out risk management, anti-corruption, conflict of interest prevention, and whistleblowing system procedures as required by internal and external legal acts.

- External resources were also updated to provide stakeholders with information on anti-corruption, conflict of interest prevention, and whistleblowing systems.

By decision of the LVRTC Management Board on October 14, 2022, all positions qualifying as public officials under the Law on Prevention of Conflict of Interest in the Activities of Public Officials were identified and reported to the State Revenue Service. A procedure was developed for employees to request approval for holding additional positions.

Transparency and equality are ensured in procurement procedures. Procurements are approved by the Director of the Finance and Administration Department, and the use of funds is monitored by the Business Control Unit. Procurement standards are approved by the Financial Analyst of the Business Control Unit and the Director of the Finance and Administration Department.

LVRTC complies with Cabinet Regulation No. 326 and the guidelines issued by the Corruption Prevention and Combating Bureau (KNAB) regarding minimum internal control system requirements for preventing corruption and conflicts of interest in public institutions. In 2022, a priority audit was carried out on Internal Control Systems for Prevention of Conflicts of Interest and Corruption, including an assessment of the whistleblowing system. The audit concluded that the internal control systems are functioning, though certain specific control gaps were identified. Overall, the controls were assessed as appropriate, sufficient, and effective, providing reasonable assurance that risks are managed and institutional objectives will be met. Audit procedures related to assessing corruption and conflict of interest risks in the procurement system were planned for 2023.

In 2022, onboarding and training were conducted for 57 new employees. During the first workweek, employees received introductory training on anti-corruption topics, and by the end of the first month, a more in-depth course on corruption and conflict of interest was provided. On August 17, 2022, training titled “Prevention of Conflict of Interest and Professional Ethics for Public Officials (Module 2 – for those with more than one year of experience as a public official)” was organized by KNAB and attended by board and council members. On September 30, 2022, all LVRTC employees participated in training “Prevention of Conflict of Interest and Professional Ethics for Public Officials (Module 1)”, covering corruption and conflict of interest risks.

In 2022, LVRTC transitioned from a permanent procurement committee model to forming ad-hoc committees for each procurement, with membership determined based on the specific subject matter of the procurement.

Multiple employees are involved in the approval of work acceptance and payment authorization processes. In 2022, the responsibilities of budget holders and other positions involved in decision-making were expanded by granting public official status (decision of LVRTC Management Board on October 14, 2022).

In 2022, a unified procedure for reporting and reviewing potential violations was introduced, including the roles and responsibilities of the Ethics Committee. Amendments were made to the Corporate Ethics Regulations.

On August 17, 2022, training titled “Prevention of Conflict of Interest and Professional Ethics for Public Officials (Module 2)” was organized by KNAB and attended by board and council members. On September 30, 2022, training on corruption and conflict of interest risks (Module 1) was conducted for all LVRTC employees.

In 2021, 36 new employees were hired and trained at LVRTC.
Within the first week of employment, the employee undergoes introductory training on anti-corruption topics.
Within the first month of employment, the employee completes an in-depth course on corruption and conflict of interest issues.
On April 16, 2021, two external training sessions were held at LVRTC for all employees on risk management topics:Risk Management in an Organization; Corruption and Conflict of Interest Risks

LVRTC has defined and approved a procedure for granting access rights, with monitoring in place to ensure compliance. In 2021, no security incidents related to this risk were identified.

Procurements are coordinated with the Director of the Finance and Administration Department. Financial monitoring of procurement groups is carried out by the Business Control Unit. Procurement standards are approved by the financial analyst of the Business Control Unit and the Director of the Finance and Administration Department.

In 2021, a total of 19 audits were carried out (9 external and 10 internal audits). An internal audit titled “Risk Management” was conducted in 2021 in accordance with the Cabinet of Ministers Order No. 47 of January 25, 2021, “On Common Audit Priorities in Public Administration for 2021,” and the guidelines for internal audit and consulting developed by the Ministry of Finance. The audit report confirmed that the corruption risks for 2021 were included in the company’s overall risk register. As a result of the audit, 13 recommendations were provided, aimed at improving: the legal framework and methodology for risk management the risk management process (risk analysis and assessment, risk treatment) employee competence and the overall culture of risk management within the organization Additionally, an emergency notification system was introduced, and a crisis management action plan was developed to help reduce risks, improve processes, and significantly enhance the internal control system as well as the effectiveness of the risk management process.