Fraud Prevention Policy
Good corporate governance that has been proposed as one of the prerequisites for long-term development of the Latvijas Dzelzceļš Group, along with mechanisms for openness and clear governance, includes a clear and unequivocal definition of conditions for timely prevention of conflicts of interest and their possible effects.
To ensure this, a Fraud Prevention Policy of the Group was approved on 4 March 2016, and a revised version of the policy was approved on 30 April 2019. Its purpose is to establish an internal control environment to prevent fraud, including corruption, as well as to detect possible fraud cases, to determine the levels of responsibility for assessment of control measures and to investigate suspected fraud cases. The policy defines the internal whistleblowing system within the Group.
The scope of the policy includes preventive and controlling measures in the event of every situation related to fraud, corruption, theft, commercial bribery, extortion, bribery as well as conflict of interest.
The Fraud Prevention Policy governs the actions of employees in contact with cooperation partners of the Group or dependent partner companies, including carrying out the assessment of cooperation partners and conduct in relation to business trips, gifts and other events potentially causing a conflict of interest. The policy determines also how an employee should act if he suspects potential fraud within the Group.
The policy complies with requirements binding on the Group that are laid down in the Whistleblowing Law and the Cabinet of Ministers’ Regulations Regarding the Basic Requirements for an Internal Control System for the Prevention of Corruption and Conflict of Interest in an Institution of a Public Person.
A whistleblower is natural person who provides information on a possible violation within the Group if the person considers this information to be true and it has become known to him or her while fulfilling the work duties or establishing legal relations related to the fulfilment of work duties at the Group’s companies or in the interest of the Group.
A whistleblower report is a report submitted in accordance with the provisions laid down in Section 3 of the Law on Submissions (https://likumi.lv/ta/id/164501-iesniegumu-likums) and indicating that it is a whistleblower report, or by using the form of the whistleblower report. The whistleblower also has to provide his or her identification data, contact information, description of the violation by providing particular facts, information regarding such natural or legal persons who may be reasonably considered as being involved in committing the violation, whether the information regarding the violation has been obtained while fulfilling the work duties or establishing legal relations related to the fulfilment of work duties, and whether this violation has been previously reported – if yes, a reply has to be added, if any has been received.
It is important for the whistleblower report to provide clear and well thought out information, as detailed as possible, and to state facts and names of the persons, as well as include copies of documents held by the whistleblower. Other evidence (such as photographs or copies of e-mail correspondence) may also be attached if they are in the whistleblower’s possession and may help in responding to the violation.
The whistleblower report may also be submitted in person at the Fraud Prevention Division of SJSC Latvijas Dzelzceļš Security Directorate.
If you would like to fill out the whistleblower report form, you can download it HERE.
After the form is filled out, it can be submitted:
- Electronically, using a secure electronic signature
- By email: email@example.com;
- In person by visiting the Fraud Prevention Division at SJSC Latvijas Dzelzceļš Security Directorate