Internal whistleblowing policy
A whistleblower is a natural person, who provides information on a possible violation and the benefit obtained from it, when performing work duties or duties equal to them at Latvijas Gāze (employees, interns and other persons, hired by Latvijas Gāze
for the performance of a service or assignment). A violation shall mean a criminal offence, administrative violation or any other violation of legal norms or ethical, or professional norms that has happened, is happening or has a reasonable possibility of happening, for example, in the following areas - fraud, bribery, tax avoidance, threat to public health, threat to labour safety, violation of human rights, violation in the financial and capital market sector, infringement of competition law etc.
Whistleblowing shall only be implemented in the case if the whistleblower has facts or information to be objectively examined and the person is ready to disclose such information. Reporting on a violation of personal interests only, knowingly giving false information or slandering of colleagues shall not be considered as whistleblowing.
Latvijas Gāze supports and promotes whistleblowing in good faith and does not refrain from it. In cases when the whistleblower does not find the need to receive anonymity guarantees or protection, the whistleblowing channel shall not remove any rights and obligations to discuss the information about the possible and occurring violations and risks related to the occurrence of such with the direct manager or assignor of the employee, or, in case of need, with the member of the board of Latvijas Gāze, supervising the work of the relevant company department.
The report of a whistleblower shall be submitted by sending it to the reporting channel of Latvijas Gāze for whistleblowing - e-mail address: trauksmes.zinojums@lg.lv.
This report should include:
- Topic: “Whistleblower’s report”.
- As much detailed information about facts, given name, surname and title of the involved person, and available or enclosed documents as possible (evidence).
- Given name, surname, title as well as contact information of the whistleblower, the use of which is preferred by the whistleblower in the case if it is necessary to contact them during the review of the report, in order to receive additional information.
- When appropriate, a notice on the fact of to whom he or she has reported the violation before, and a copy or abstract of the reply, if any has been received.
The maximum period of review of the report and, if necessary, adoption of the final decision shall be three months.
The recipient of the report and all persons involved in the further process of evaluation of the report, in order to ensure protection of the whistleblower against any adverse consequences caused due to whistleblowing, shall have an obligation to protect the identity of the whistleblower - given name, surname, contact information and any other data that would enable one to identify the whistleblower. It is prohibited to disciplinarily or otherwise punish the whistleblower and his or her relatives, to discharge them from work or the office, to reduce in rank, to move to other work or a different position or otherwise directly or indirectly cause to them or adverse consequences, due to the fact that the whistleblower has given the whistleblower’s report. Such protection requirements shall also be in force in the case if the whistleblowing is made through external authorities or public channels. The whistleblower shall not be exempt from potential sanctions, if the whistleblower him or herself has committed a violation.
Personal data of the whistleblower, the report, the enclosed written or material evidence, documents prepared by the committee and correspondence, as well as related decisions and orders shall have the status of restricted information.
Information about the internal whistleblowing system of Latvijas Gāze shall be provided to every employee, upon the commencement of legal employment relations, and shall be constantly available to all employees on the public use document disk and/ or employee self-service portal of Latvijas Gāze. The relevant internal procedure shall be issued to the whistleblower, who is not an employee of Latvijas Gāze.