Report Wrongdoings
ConnectPay does not tolerate wrongdoings within the Company, with clients and partners. Thus, we expect you to inform us if any wrongdoing has happened. ConnectPay expects you to inform us in cases of:
- offences that have been, are being or are likely to be committed;
- non-compliance with the laws;
- miscarriage of justice;
- attempt to bribe or act of corruption activities;
- act or omission that is discriminatory, grossly negligent or constitutes gross mismanagement;
- fraud, financial malpractice, or impropriety;
- criminal activity, including bribery and corruption;
- attempts to destroy any information of wrongdoing;
- attempts of tipping off;
- improper, unethical behaviour of ConnectPay representatives;
- personal grievances (e.g. bullying, harassment, discrimination).
- The above list is a non-exhaustive list of examples.
ConnectPay provides you with a safe and secure mechanism to raise concerns and report any wrongdoings within the ConnectPay that you become aware of. You are invited to report through [email protected]. The email will be reviewed by the relevant ConnectPay employee, and you will be informed of the investigation progress.
Guarantees & Confidentiality
Anonymously expressed concerns are much less credible and more difficult to investigate, therefore ConnectPay encourages you to reveal your identity. We guarantee that the reporting parties will not be discriminated against or experience any other negative impact because of their concerns raised. Unless the reporting party has expressly agreed on disclosure of his/her identity in a course of the investigation, including explicit agreement to disclose his/her identity to the competent authorities, ConnectPay, in case of transfer of the concern to the competent authority, will depersonalize the data of the concern. ConnectPay may be obliged by the mandatory rules of law to reveal the identity of the reporting party in a course of subsequent investigations and the reporting party may need to provide a statement as part of the evidence required.
All information that was revealed by the reporting party and/or became known during the investigation of wrongdoing will not be disclosed to any third parties before the investigation is completed, except the Senior Management of the company or competent authorities and officials, when needed. Identifying data of the reporting party or the person suspected in wrongdoing can be provided only to the person or institution which examines the concern, however in each case with prior notification to the reporting party thereof specifying the reasons for such disclosure. ConnectPay will not be bound by the confidentiality obligations stipulated above if the reporting party has provided knowingly false information. ConnectPay ensures that all personal data collected during the investigation procedure will be managed in accordance with the Company’s Employee Personal Data Protection Policy.
Raising Concern to Competent External Parties
The reporting party can bring his / her concerns to light by contacting the Bank of Lithuania or other competent external authorities. Such reporting should be performed as defined by the Law on Whistle-blowers Protection of the Republic of Lithuania, in cases when:
- concern may have a critical impact on public interest;
- concern may cause major damage;
- concern may involve Senior Management or/and Shareholder(-s);
- Internally submitted report was not acted upon or provided unsatisfactory results;
- It is likely that confidentiality may not be kept when reporting through internal channels or that concern would not be sufficiently investigated trying to hide it, or the reporting party would be pressured otherwise.