Corporate Ethics

1.1. The purpose of the Corporate Code of Ethics of the state joint stock company “Latvia State Radio and Television Center” (LVRTC) is to define:
1.1.1. the fundamental principles of good commercial practice and employee professional ethics and conduct;
1.1.2. the conditions for holding additional positions or employment with another employer;
1.1.3. the rules for giving and receiving gifts and donations;
1.1.4. the procedures for preventing conflicts of interest;
1.1.5. how the opportunity to report potential violations in accordance with the Whistleblowing Law is ensured;
1.1.6. the procedure for reviewing whistleblower reports and employee submissions related to possible violations of ethical principles and standards.

1.2. These rules are binding on all employees of the state joint stock company “Latvia State Radio and Television Center”.

Secondary Employment

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.

Employee

An LVRTC employee or any other person engaged by LVRTC under an employment contract or acting in LVRTC's interests under a service, mandate, contract, or other agreement. Includes members of the Supervisory Board, Management Board, the trade union chairperson, and staff.

Gift

Any material or other benefit (including services, granting of rights, transfer, exemption from obligations, waiver of rights, or any other action that results in a benefit) received directly or indirectly by an employee.

Donation

Transfer of LVRTC financial resources or property, including goods and/or services, free of charge to another party for specific purposes.

DVS

Document Management System of the state joint stock company “Latvia State Radio and Television Center”.

Horizon HoP

Employee self-service portal of the state joint stock company “Latvia State Radio and Television Center”.

Submission

An application reviewed by the Permanent Ethics Commission regarding a potential violation of employee ethical principles and rules, if it is not considered a whistleblower’s report or a submission under the Law on Submissions.

Conflict of Interest

A situation where an employee, in the course of performing official duties, must make or influence a decision, or perform actions related to those duties, that affect or could affect their own, a relative’s, or a business partner’s personal or financial interests.

Law on Conflict of Interest

Law "On Prevention of Conflict of Interest in Activities of Public Officials".

INTRA

Information Management System of the state joint stock company “Latvia State Radio and Television Center”.

JD

Legal Department.

Client

A natural or legal person who has entered into an agreement with LVRTC for the provision of specific electronic communications services or who initiates the process of entering into such an agreement.

LVRTC

State Joint Stock Company “Latvia State Radio and Television Center”, registration No. 40003011203, Zemitāna iela 9 k-3, Rīga, Latvia, LV-1012.

Hate Speech

Public statements that promote, incite, justify, or provoke hatred or violence against a person or group identifiable by characteristics such as race, ethnicity, gender, age, sexual orientation, beliefs, or health status, aimed at undermining their dignity and honor.

Rules

Corporate Code of Ethics of LVRTC.

PAD

Personnel Development Department.

Supervisory Board

Supervisory Board of the state joint stock company “Latvia State Radio and Television Center”.

Violation

A criminal offense, administrative violation, or other legal infringement (act or omission), including actions that contradict the purpose of legislation, as well as breaches of binding ethical or professional conduct standards.

Partner

A commercial company, institution, or organization that performs work or provides services based on an agreement with LVRTC.

Permanent Ethics Commission

A permanent commission established by LVRTC that: reviews whistleblower reports in accordance with the Whistleblowing Law, the LVRTC Corporate Code of Ethics, and other applicable laws; examines employee submissions regarding potential violations of ethical principles by other employees; performs other duties defined by the LVRTC Organizational Structure Management Regulations.

Relative

The employee’s spouse, relative or in-law up to the second degree of kinship or first degree of affinity, or a domestic partner with whom the employee has shared a household and mutual personal or financial interests for at least one year.

Register

Register of permits for secondary employment and holding additional positions.

Associated Person (within the meaning of the Whistleblowing Law)

A natural person who supports or assists a whistleblower in whistleblowing or is otherwise connected to the whistleblower and could suffer adverse consequences. This may include a business entity owned by, employing, or otherwise associated with the whistleblower.

Direct Supervisor

The head of an LVRTC department to whom the employee directly reports in an employment relationship.

Whistleblower

A natural person who provides information about a potential violation that may harm public interest, which they believe to be true and have obtained through work-related duties or legal relationships, including internships, and who may suffer adverse consequences as a result.

Whistleblower Report

A report submitted under the Whistleblowing Law.

Management Board

Management Board of the state joint stock company “Latvia State Radio and Television Center”.

Public Official

An LVRTC employee who meets the criteria set by the Law "On Prevention of Conflict of Interest in Activities of Public Officials".

Report

A submission, within the meaning of the Whistleblowing Law, that has not yet been formally recognized as a whistleblower report.

3.1. In cases not regulated by these Rules, the Employee shall act in accordance with the provisions of external regulatory enactments, the general basic principles of ethics, and standards of conduct.

3.2. The Employee shall observe the ethical principles and basic requirements of conduct set forth in these Rules even outside the place and time of performing official duties.

3.3. The Employee of LVRTC primarily resolves ethical issues with their direct supervisor. The person of trust for ethical matters is the Head of PAD, who provides consultations to Employees on ethics-related issues, promoting a common understanding and resolving unclear situations.

3.4. For violations specified in these Rules, the Employee may be held disciplinarily liable, required to compensate for damages, or the matter may be referred to another competent authority, including law enforcement authorities.

4.1. In providing its services, LVRTC operates honestly, ethically, and in accordance with regulatory enactments. LVRTC expects its Partners to comply with these principles as well.

4.2. By observing corporate ethics standards, LVRTC creates a favorable environment aimed at long-term cooperation with its Partners and Clients.

4.3. LVRTC respects human rights, supports safe working conditions, and does not tolerate corruption.

4.4. In its activities, LVRTC observes the decisions of the shareholder and the Council.

4.5. RELATIONS WITH PARTNERS

4.5.1. LVRTC establishes professional and mutually constructive relationships with its Partners to ensure that the services provided to clients are of the required quality and in accordance with regulatory requirements and the concluded contract.

4.5.2. LVRTC highly values long-term cooperation with existing Partners and is also open to new Partners.

4.5.3. LVRTC builds cooperation with its Partners based on trust and mutual agreement.

4.5.4. LVRTC expects Partners to observe the principles of fair competition in their field of activity.

4.6. RELATIONS WITH CLIENTS

4.6.1. LVRTC is a client-oriented company that ensures the availability of services in accordance with regulatory enactments.

4.6.2. LVRTC aims to be the first choice for its Clients in service provision. LVRTC treats Clients with integrity.

4.6.3. LVRTC is open to suggestions and proposals for improving the efficiency of its operations and the services provided.

4.7. RELATIONS WITH EMPLOYEES

4.7.1. Honest employment relations. LVRTC operates in accordance with the regulatory enactments governing employment relations. LVRTC takes measures to create an attractive employer image for potential Employees as well. LVRTC selects Employees according to their competence, professionalism, and values. LVRTC provides remuneration for work performed with quality and in accordance with regulatory enactments.

4.7.2. Equality and acceptance of diversity. LVRTC applies the principle that respect is the basis of personal and work relationships. LVRTC aims to form a team and create a work environment where Employees are respected and not discriminated against. Employees' work is evaluated based on their work results and approach and execution of work. LVRTC does not tolerate discrimination, humiliation, harassment, violence, or insults against Employees or other persons with whom cooperation is established. Employees treat each other with respect and kindness.

4.7.3. Health and safety. LVRTC ensures safe and health-friendly working conditions, constantly improves them, ensures the safety of work processes, considers harmful and dangerous factors of the work environment, and implements preventive measures. Safety regulations established by external and internal regulatory enactments are observed in the LVRTC work environment.

4.7.4. Privacy. LVRTC respects the privacy of Employees. LVRTC follows the principle that an Employee’s private life should not conflict with LVRTC’s efforts to ensure legality and integrity of operations.

5.1. In interactions with colleagues and clients, the Employee treats others with respect, observing the rights and lawful interests of every person. The Employee is polite and courteous, does not use offensive language, does not insult the honor of others, and is tolerant of the views and beliefs of others.

5.2. The Employee is not arrogant or authoritarian in relationships with colleagues, listens to the opinions of others, and evaluates them professionally.

5.3. The Employee is responsive and cooperates with colleagues, providing and receiving necessary support in the performance of professional duties, respecting the Employee’s competence in the specific matter and the requirements set in the job description, and does not abuse the trust of colleagues.

5.4. When making decisions or participating in decision-making, expressing and defending their opinion within their competence, the Employee considers the principles and guidelines defined in these Rules.

5.5. The Employee undertakes to:

5.5.1. outside the performance of official duties, act in a way that does not discredit LVRTC and their own activities (position), and avoid posting offensive, compromising, or hostile entries and/or materials (photos, videos) on websites or social networks;

5.5.2. observe business etiquette and work culture, with proper behavior, appearance, and actions that would promote justified public trust in LVRTC;

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

5.5.4. not exploit colleagues’ or other persons’ lack of knowledge or mistakes in specific work matters for malicious purposes, but instead point them out correctly and improve them according to the requirements set in the colleague’s job description;

5.5.5. be able to admit and correct their own mistakes and improper actions in work execution and relationships with other colleagues or clients; inform colleagues about professionally relevant topics and experiences that could also be useful to other Employees.

5.6. Employees performing managerial duties at LVRTC, in addition to the duties set out in this section:

5.6.1. always act in accordance with the requirements they set for their subordinates;

5.6.2. promote Employees’ understanding of LVRTC’s mission, mobilize them for common interests, and foster mutual trust;

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

5.6.4. encourage Employees to participate in the development of LVRTC, promote their professional growth and initiative, interest in fulfilling duties, and improving performance;

5.6.5. promote the succession of professional knowledge, onboarding of new Employees, and their development;

5.6.6. provide criticism of an Employee’s work individually, with justification. When giving positive feedback on team performance, emphasize the importance of cooperation in achieving common goals;

5.6.7. regularly evaluate their own and Employees’ activities, Employee engagement, and client satisfaction to continuously improve LVRTC’s work.

6.1. An Employee may not perform job duties if employment with another employer creates suspicions of potential, apparent, or actual conflicts of interest that hinder the fulfillment of tasks and functions assigned by LVRTC.

6.2. The Employee is obliged to immediately inform their Direct Manager of the emergence of apparent or actual conflicts of interest or in cases where there is suspicion that such a situation might arise. Before combining positions or undertaking secondary employment, any case of combining positions or secondary employment must be coordinated as follows:

6.2.1. Employees working in units subordinate to departments – with the direct manager and the department director;

6.2.2. Employees working in units subordinate to the board – with the direct manager and the responsible board member;

6.2.3. Heads of units subordinate to departments – with the department director and the responsible board member;

6.2.4. Department directors and heads of units subordinate to the board – with the responsible board member.

6.3. For Employees who are public officials, the restrictions on combining positions and earning income are determined by the Law on Prevention of Conflict of Interest, the Work Regulations, and the Corporate Ethics Rules governing this area.

6.4. The Employee is responsible for complying with the requirements regarding combining positions, secondary employment, and earning income as set out in the Law on Prevention of Conflict of Interest and these Rules.

6.5. The Employee must ensure that combining positions or secondary employment does not create a conflict of interest, violate ethical standards, or interfere with the performance of direct job duties.

6.6. The coordination of combining positions or secondary employment is carried out in accordance with the description of the sub-process “Coordination of Combining Positions and Secondary Employment” within the “Personnel Management” process.

6.7. The Employee submits an application for combining positions or secondary employment in Horizon HoP and sends it to the direct manager for approval.

6.8. If the Employee’s direct manager determines that combining positions or secondary employment does not create a conflict of interest, violate ethical standards, or interfere with the performance of direct job duties, they approve the Employee’s application in Horizon HoP.

6.9. If the Employee’s direct manager determines that combining positions or secondary employment creates or may create a conflict of interest, violates ethical standards, or interferes with the performance of direct job duties, they do not approve the Employee’s application in Horizon HoP, stating the reason for rejection.

6.10. The Employee must submit the application mentioned in Clause 6.7 in Horizon HoP no later than:

6.10.1. Two weeks before appointment to a public official position at LVRTC, if simultaneously holding another position (performing an authorization, company contract, or conducting economic activity);

6.10.2. Within seven days from the determination of public official status, if the Employee already holds a position at LVRTC that is assigned public official status and simultaneously holds another position (performs an authorization, company contract, or conducts economic activity);

6.10.3. Two weeks before starting secondary employment or combining positions (entering into a company contract, assuming an authorization, or starting economic activity);

6.10.4. Within seven days from starting job duties at LVRTC, if the Employee is already engaged in other secondary employment or holds another position.

6.11. The Employee receives approval for combining positions or secondary employment separately for each position or secondary job.

6.12. Approval for combining positions or secondary employment is granted for the period indicated in the Employee’s application, or for up to one year if no specific term is indicated. If the Employee wishes to continue combining positions or secondary employment after the specified term, a new application must be submitted.

6.13. The Employee is responsible for monitoring the term specified in Clause 6.12.

6.14. If, while combining positions or performing secondary employment, new circumstances arise that may affect the previous approval, the Employee must immediately inform their direct manager.

6.15. If the direct manager determines that the approved combination of positions or secondary employment interferes with the proper and compliant performance of direct job duties as set out in these Rules, or if an obvious conflict of interest or violation of ethical standards has arisen, the direct manager shall discuss the matter with the Employee and, if necessary, prepare a submission to the responsible board member for revocation of the approval.

6.16. After the approval for combining positions or secondary employment is revoked, the Employee must, within one month, assess the possibility of terminating the combination of positions or secondary employment and inform the direct manager about the termination. If the Employee refuses to terminate the combination of positions or secondary employment, further fulfillment of the Employee’s job duties at LVRTC will be resolved according to these Rules, other internal regulations, and the procedures set by the Labor Law.

6.17. For the purpose of evaluating the Employee’s application for combining positions or secondary employment, the direct manager has the right to request and receive information from other LVRTC structural units and databases.

6.18. The register of Employee applications and their approvals or rejections is maintained in Horizon HoP and managed by PAD.

6.19. PAD provides information from the Register to other structural units about a specific employee’s secondary employment or combination of positions, observing personal data protection requirements, and provides information only to the extent necessary to identify and/or prevent conflicts of interest, violations of ethical standards, or interference with direct job duties.

6.20. The Risk Manager, at least once every two years, conducts a review of the compliance of declared secondary employment and combination of positions of officials and employees with the information available to LVRTC in the register of employee applications and their approvals or rejections, as well as with publicly available information. The Risk Manager submits the established facts to the Head of PAD, who, in case of discrepancies, contacts the specific employee and their direct manager to resolve the situation

7.1. An Employee, including a public official, when performing duties at LVRTC, must avoid and/or refrain from carrying out any activities or tasks in which they themselves, their relatives, or business partners have a personal or financial interest, unless two years have passed since the termination of such business relationships.

7.2. If an Employee, including a public official, must make a decision or perform other actions related to their official duties that affect or may affect their own, their relatives', or business partners' personal or financial interests, or if, for ethical reasons, the Employee's objectivity and impartiality could be questioned, the Employee must refuse to make such a decision or perform such actions, and must inform (either verbally or in writing by email) their direct manager, stating the reason. The direct manager appoints another Employee to make the decision, or informs the board if a board decision is required.

7.3. If the Employee or their relative has received a gift exceeding the value of 20 minimum monthly salaries from a natural or legal person whose interests are affected by the Employee's decision within the last two years, the Employee must refuse to make such a decision or perform such actions, and must inform their direct manager, stating the reason

8.1. In accordance with the Whistleblowing Law, LVRTC has established an internal whistleblowing system.

8.2. A whistleblower is entitled to raise concerns about possible, occurred, or ongoing violations discovered while performing work duties, which are not of an individual nature and are raised for the benefit of society or a part thereof, especially regarding violations in the following areas:

8.2.1 Inaction, negligence, abuse of official position, or other unlawful actions by officials;

8.2.2. Corruption, as well as violations of political organization (party) and association financing rules and pre-election campaigning restrictions;

8.2.3.Misuse of public financial resources or property;

8.2.4. Tax evasion;

8.2.5. Threats to public health;

8.2.6. Threats to food safety;

8.2.7. Threats 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. Threats to occupational safety;

8.2.11. Threats to public order;

8.2.12. Human rights violations;

8.2.13. Violations in public procurement and public-private partnership;

8.2.14. Violations in the financial and capital market sector, including fraud and other illegal actions endangering the financial interests of the European Union;

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

8.2.16. Violations of competition law and business support rules;

8.2.17. Violations in the provision of goods and services, including related to safety and compliance;

8.2.18. Violations in transport safety;

8.2.19. Violations related to the internal market;

8.2.20. Consumer rights protection;

8.2.21. Protection of private life and personal data, and network and information systems security;

8.2.22. Hate speech;

8.2.23. Other violations specified in the Whistleblowing Law.

8.3. If an Employee becomes aware of or witnesses any of the violations mentioned in 8.2, or observes another Employee acting contrary to external or LVRTC internal regulations, the Employee is obliged to report this to the Permanent Ethics Committee.

8.4. Reports to the Permanent Ethics Committee may be submitted in free form, indicating that it is a whistleblower report and addressed to the Permanent Ethics Committee, or by using the whistleblower report form (Annex No.1, also available in the LVRTC information management system INTRA section "Internal Whistleblowing System").

8.5. The whistleblower submits a report on the violations mentioned in 8.2 in accordance with Article 3 of the Law on Submissions (indicating information about the submitter - name and surname, as well as address and, if necessary, other contact details).

8.6. The LVRTC contact person for whistleblowing is the Risk Manager, who also provides consultations to employees and is registered with the State Chancellery.

8.7. Possible reporting channels (indicating that it is a whistleblower report and addressing it to the Permanent Ethics Committee):

8.7.1. Electronically – by email to , available 24/7 (if necessary, the general LVRTC correspondence email can also be used);

8.7.2. In paper form – to the office and personnel administrator or PAD manager, available 8/5;

8.8. In the whistleblower report regarding violations mentioned in 8.2, the Employee identifies the possible violator, stating known facts and considerations. The Employee may use the whistleblower report form (Annex 1) or submit the report electronically without a secure electronic signature via the national administration services portal www.latvija.lv or the website www.trauksmescelejs.lv, if the whistleblower's identity is verified using the online forms available on the portal and website.

8.9. If the whistleblower has reason to believe that reporting internally at LVRTC may endanger themselves or is otherwise ineffective, the whistleblower report regarding violations mentioned in 8.2 may also be submitted outside LVRTC:

8.9.1. By contacting the competent authority (list available at www.trauksmescelejs.lv);

8.9.2. By contacting the whistleblower contact point at the State Chancellery (contacts available at www.trauksmescelejs.lv);

8.9.3. By contacting an association or foundation (including a trade union or trade union association).

8.10. Whistleblowing may also be carried out by providing information publicly if at least one of the following conditions applies:

8.10.1. Within two months of the submission being recognized as a whistleblower report, the whistleblower is not informed about the progress of their report;

8.10.2. The violation indicated in the whistleblower report is not remedied for a long time without objective reason;

8.10.3. The person has reason to believe that the violation may be irremediable or poses an unmistakable threat to public interest;

8.10.4. The person has reason to believe that contacting the competent authority will result in adverse consequences, the violation will be concealed, or not remedied.

8.11. Knowingly providing false information, disclosing state secrets, information about special investigative activities or their results, information about consultations with employee representatives or trade unions, as well as reporting solely for personal interest is not considered whistleblowing.

8.12. Anonymous reports regarding violations mentioned in 8.2 are examined in accordance with the procedures set by the Law on Submissions.

8.13. From the moment whistleblowing is performed, LVRTC ensures the following protection guarantees for the whistleblower, their relatives, and associated persons:

8.13.1. Protection of identity;

8.13.2. Protection against adverse consequences resulting from whistleblowing, including against the following actions by LVRTC:

8.13.2.1. Disciplinary or other punishment;

8.13.2.2. Dismissal or non-renewal of employment contract or non-appointment to a permanent position, if there was reason to believe this would occur;

8.13.2.3. Transfer to another job or position;

8.13.2.4. Denial of promotion, professional training, or qualification improvement;

8.13.2.5. Change of job duties, working hours and location, or remuneration;

8.13.2.6. Negative evaluation of work or duties;

8.13.2.7. Damage to honor, dignity, and reputation;

8.13.2.8. Revocation of licenses and permits;

8.13.2.9. Unilateral withdrawal from or termination of contracts for supply, purchase, or service provision;

8.13.2.10. Requirement for a medical opinion;

8.13.2.11. Any other direct or indirect adverse consequences, including violation of the principle of equal treatment.

8.14. From the moment whistleblowing is performed, the whistleblower, their relatives, and associated persons also have the right to other state-level protection guarantees (consultations available at www.trauksmescelejs.lv)

9.1. The activities, structure, functions, and tasks of the Permanent Ethics Committee are defined by the LVRTC Organizational Structure Management Regulations.

9.2. Principles of operation of the Permanent Ethics Committee:

9.2.1. Integrity – In its activities, the Permanent Ethics Committee acts with accuracy and honesty, plans, and anticipates the results of its actions;

9.2.2. Neutrality – The Permanent Ethics Committee maintains a neutral position during its activities and when making decisions;

9.2.3. Benevolence – The Permanent Ethics Committee listens to the persons involved in the case or matter under review in a benevolent and encouraging atmosphere;

9.2.4. Objectivity – The Permanent Ethics Committee examines submissions or whistleblower reports objectively and fairly, observing equality before the law for all persons and not showing special favor or privileges to any specific person involved in the case;

9.2.5. Responsibility and reasoning – The Permanent Ethics Committee acts only with reasoned actions, and is responsible for the process and results of its activities;

9.2.6. Independence – The Permanent Ethics Committee is independent in its activities, decision-making, and in providing opinions;

9.2.7. Confidentiality – Confidentiality and personal data protection requirements are maintained during the review of submissions or whistleblower reports. Members of the Permanent Ethics Committee are prohibited from disclosing information obtained while working in the Committee, except in cases provided for by law.

10.1. The Permanent Ethics Committee has the following rights:

10.1.1. To request and receive information and explanations from Employees within its competence, observing the document circulation procedures established by LVRTC;

10.1.2. To summon Employees mentioned in submissions or whistleblower reports, or others involved in the Committee’s review, to Committee meetings to provide clarifications;

10.1.3. To make decisions or provide opinions in accordance with the procedures defined in these Rules and other internal and external regulatory enactments.

10.2. The Permanent Ethics Committee is responsible for:

10.2.1. Fulfilling the tasks specified in the Organizational Structure Management Regulations, these Rules, and other internal and external regulatory enactments;

10.2.2. Ensuring its decisions comply with the Organizational Structure Management Regulations, these Rules, and the requirements of other external and internal regulatory acts.

10.3. Any member of the Permanent Ethics Committee may be removed from the Committee by a decision of the Board or may voluntarily resign from their duties as Chairperson or member by submitting a resignation request to the Board.

11.1. The office and personnel administrator registers submissions or whistleblower reports that fall within the competence of the Permanent Ethics Committee and records them in the DVS (Document Management System) as restricted-access information, ensuring access only for members of the Permanent Ethics Committee. Whistleblower reports are separated from other documentation and assigned a distinct identifier.

11.2. The office and personnel administrator forwards the submission or whistleblower report in the DVS to the Chairperson of the Permanent Ethics Committee for review.

11.3. If the information included in the Employee’s submission or whistleblower report concerns a member or the Chairperson of the Permanent Ethics Committee, the office and personnel administrator ensures that the submission is not directed to the respective Committee member or Chairperson. The Chairperson of the Permanent Ethics Committee or their substitute informs the Board, and the Board decides on the appointment of another Committee member to serve until the circumstances preventing participation are resolved. Conflict of interest situations are resolved in accordance with internal and external regulatory enactments on the prevention of conflicts of interest.

11.4. Members of the Permanent Ethics Committee, the office and personnel administrator, or any Employee who, in the course of their duties (e.g., system administrator), has access to the DVS or any other LVRTC system documentation related to the review of a submission or whistleblower report, are prohibited from disclosing information that reveals the identity of the individual or legal entity reported by the submitter or whistleblower, as well as information about the submitter or whistleblower themselves. Such information may only be provided to a person or institution that requires it for the review of the whistleblower report or the investigation of a violation initiated on its basis, or for the protection of the whistleblower, their relative, or associated person, as well as if provided for by external regulatory enactments.

11.5. Before reviewing a submission or whistleblower report, members of the Permanent Ethics Committee must confirm, in accordance with regulatory enactments, that they have no interest in the review of the submission or whistleblower report (personally or by virtue of hierarchical subordination), or must immediately inform the Chairperson or their substitute of any circumstances that prevent them from confirming non-involvement.

11.6. All persons (not only members of the Permanent Ethics Committee) involved in the review and investigation of a submission or whistleblower report must comply with requirements regarding neutrality and confidentiality, as well as the protection of the whistleblower, their relatives or associated persons, personal data protection, and other requirements in accordance with these Rules and other regulatory enactments.

11.7. Whistleblower reports are reviewed by the Permanent Ethics Committee in accordance with the procedure specified in Annex 2 of the Rules, “Special Procedure for Reviewing Whistleblower Reports.”

11.8. Submissions related to violations of ethical principles and standards of conduct are reviewed by the Permanent Ethics Committee in accordance with the procedure specified in Annex 3 of the Rules, “Special Procedure for Reviewing Submissions on Possible Violations of Ethical Principles and Standards of Conduct.”

11.9. Within three working days after receiving a submission or whistleblower report, the Chairperson of the Permanent Ethics Committee sets the date for the Committee meeting and notifies the Committee members.

11.10. Meetings of the Permanent Ethics Committee may be held in person, remotely, or in a hybrid format. Meetings are convened by the Committee Chairperson.

11.11. The minutes of the Committee meeting are taken by a Committee member designated by the Chairperson. The minutes must indicate:

11.11.1. The location and time of the Committee meeting;

11.11.2. The participants of the Committee meeting;

11.11.3. The course and content of the discussion;

11.11.4. The decisions made.

11.12. The minutes of the Committee meeting are prepared within three working days after the date of the meeting.

11.13. The Permanent Ethics Committee records procedural decisions and votes in the minutes of the Committee meeting. The vote on the adopted opinion is recorded in the opinion itself.

11.14. The opinion of the Permanent Ethics Committee is of a recommendatory nature for the Employee, the Employee’s direct manager, the head of the structural unit, or the Board.

11.15. The opinion may include recommendations regarding:

11.15.1. Holding the Employee disciplinarily liable if the Committee identifies signs of a disciplinary violation in the Employee’s actions;

11.15.2. The implementation of corrective actions and/or additional control mechanisms in LVRTC operations;

11.15.3. Any other recommendations for LVRTC and its Employees.

11.16. The opinion on the outcome of the review of a whistleblower report or a submission regarding a possible violation of ethical principles or standards of conduct is submitted by the Permanent Ethics Committee to the Board for consideration within three working days from the adoption of the opinion.

11.17. The opinion of the Permanent Ethics Committee is signed by all Committee members who participated in the preparation of the opinion.

12.1. The Head of the Accounting Department updates and submits the list of LVRTC public officials to the State Revenue Service within the timeframe specified by the Law on Prevention of Conflict of Interest.

12.2. The KPD Risk Manager, at least once every three years, together with the heads of structural units, re-evaluates the functions and positions at LVRTC that are exposed to corruption risks.

12.3. The identification, assessment, determination of mitigating measures, and control of LVRTC corruption risks are carried out in accordance with the procedures specified in the Risk Management Regulations.

12.4. The KPD Risk Manager publishes information on the implementation of the previous year’s anti-corruption action plan on the LVRTC website each year, but no later than three months after the approval of the annual report.

12.5. The anti-corruption action plan is reviewed and, if necessary, amended once a year.

12.6. The anti-corruption action plan may also be reviewed and amended in the event of extraordinary circumstances, such as cases of conflict of interest or corruption.

12.7. In the event of conflicts of interest and corrupt violations committed by public officials, LVRTC immediately informs the competent authority (the Corruption Prevention and Combating Bureau, the State Revenue Service, the Constitution Protection Bureau, or another competent authority).

13.1. LVRTC does not accept donations (gifts).

13.2. LVRTC does not plan to make donations (gifts).

13.3. Donations (gifts) may be made in exceptional cases by a separate decision of the Board only if all the conditions for making donations (gifts) specified in Annex 4 of the Rules are fulfilled.

13.4. The LVRTC Board may make a separate decision to make donations even if not all the conditions specified in Annex 4 of the Rules are met, insofar as this is in accordance with the requirements of regulatory enactments and the applicable special legal regulations in force at that time.

14.1. The KPD is responsible for the management of these Rules.

14.2. Amendments to the Rules are made in the event of changes in the regulatory enactments of the Republic of Latvia or improvements to the LVRTC quality management system.

14.3. The Rules enter into force after their approval at the LVRTC Board meeting in accordance with the procedure specified in the Board’s decision.

14.4. The current version of the Rules is maintained electronically in the DVS (Document Management System).