Viciunai Group, being a significant part of Lithuanian and international business and society, and being aware of its responsibility to its customers, suppliers, employees and the society, undertakes to comply with the requirements of the national and international legal acts regulating its business activities, the highest standards of business ethics, the principles of transparent business and the policy of corruption prevention.
This Transparency and Business Ethics Policy is an integral part of the Vision and Values, Food Safety and Quality, Environmental Protection, Occupational Health and Safety, Human Rights and Social Responsibility of Viciunai Group and applies to all employees in employment relationships with companies in Viciunai Group, including companies outside the Group, but in which any company in the Group holds shares and their affiliates, in the company's relations with third parties (customers, suppliers, partners, state or municipal authorities or bodies, etc.). It is publicly available and accessible to our customers, suppliers, business partners, the public and other stakeholders.
TRANSPARENCY PRINCIPLES
In order to prevent any potential corruption, we are committed to the following principles of transparent and ethical business conduct:
· Compliance with legal provisions and standards of conduct
We comply with national and international laws and regulations, including the prevention of corruption. In situations where this Policy, laws or regulations do not prescribe appropriate standards of conduct, we shall conduct ourselves in a manner that is consistent with socially accepted standards of honest and ethical behaviour.
· Transparency and disclosure of business accounts
We ensure that our activities and objectives are transparent and clearly stated. We disclose information about the company's activities in accordance with the country's legal requirements and ensuring the protection of confidential information and the interests of all stakeholder groups.
The Company's business accounting is accurate, all transactions are correctly reflected, and we strictly comply with all applicable legislation and business accounting standards.
· Prohibition of influence peddling and bribery
We strictly prohibit all forms of influence peddling and bribery in the Company's business, and we do not offer, solicit or accept bribes or other material benefits.
If signs of influence peddling or a request or offer to accept a bribe are detected, the person responsible for preventing corruption in the Company and the law enforcement authorities are informed.
· Avoiding conflicts of interest
We avoid and do not tolerate situations where there may be a conflict between an employee's responsibilities towards the Company and his/her personal interests. The Employee must avoid any circumstances which could damage the Company's reputation or other material or immaterial interests. Business transactions are concluded in the best interests of the Company.
In our relations with the public sector, we act transparently, under conditions of free competition, avoiding potential conflicts between private and public interests and any appearance of influence peddling.
· Intolerance of nepotism
The Company does not protect family members, relatives and other related persons in relationships of direct command and control. Employees are selected fairly, on the basis of competence and performance, and working conditions and remuneration for employees in the same function are comparable and commensurate with their work and competence.
In order to avoid any misunderstandings or ambiguous situations, we make it clear that we do not provide or accept gifts that could be construed as an incentive or reward for a decision, or as a favour or as a request for exclusive treatment.
Only symbolic representative gifts for corporate purposes are allowed to maintain business relations.
By informing customers and suppliers about our transparent gift policy, we help ourselves and our suppliers do the right thing.
· Provision of support
The Company does not tolerate the provision of support that could be perceived as bribery or influence peddling.
· No tolerance of fraud and forgery
We aim to identify and prevent all forms of fraud, intentional and unlawful deception for financial or personal gain, unfair or unlawful advantage.
· Free competition for suppliers
All our procurements are transparent and we ensure a level playing field for suppliers. Suppliers, their products and services, are selected only on the basis of criteria set out in internal procedures, and all forms of bribery and corruption are not tolerated.
· Prevention of international sanctions and restrictions
We strive to ensure that we work only with trusted business partners who are not subject to international sanctions or restrictions.
POLICY IMPLEMENTATION, MONITORING AND CONTROL
The management of the Viciunai Group undertakes to devote the necessary resources to the implementation of this Transparency and Business Ethics Policy and is committed to upholding these principles of transparent business conduct and to continuously monitor compliance with these commitments in the day-to-day operations of Viciunai Group.
The Company's management and heads of structural units shall, by their conduct, shape the standards of conduct set out in the Policy and ensure that activities in the areas of their responsibility are carried out in a manner that properly implements the provisions of this Policy. The heads of the Company's structural units are responsible for ensuring that the Policy and the Company's internal documents implementing it are duly communicated to subordinate employees and other persons accountable to them.
We continuously monitor compliance with the principles of this Policy and implement monitoring and control systems. Any irregularities detected shall be brought to the attention of the immediate supervisor or the Company's designated person in charge. Also, in order to ensure proper implementation of the provisions of the Policy, prevention of violations, transparency and trust, the Company has established a Transparency Line by tel. No. +37052103300 and by e-mail transparency@vici.eu for confidential reporting of violations of the Policy and for obtaining the necessary information related to its implementation.
The Company guarantees the confidentiality of whistleblowers and takes all measures to protect whistleblowers from any possible negative consequences.
We ensure that all potential violations of the Policy are properly investigated, evaluated and resolved. Actions found to be inconsistent with the provisions of the Policy or to constitute Corruption may result in disciplinary action, including termination of employment.
We aim to ensure that all our suppliers, contractors, subcontractors, service providers, users, consultants, advisors, intermediaries, beneficiaries, persons acting on the Company's behalf and other business partners comply with the requirements of this Policy in the Company's activities.
