Whistleblower Protection

Reports about potential violations may be submitted by individuals who are associated with the state-owned enterprise Lithuanian Airports, if they:

• work for the Company under an employment or civil contract;
• are associated with the Company through pre-contractual relationships;
• participate in the recruitment or hiring process;
• belong to the Company’s administrative, management, or supervisory bodies
• (including members without executive powers, volunteers, paid or unpaid interns);
• work under the supervision of or manage contractors, subcontractors, and/or suppliers;
• are otherwise related to the Company’s activities.
  
  If you notice legal violations that pose a threat to the public interest or infringe upon it, you are encouraged to report them.

A violation is considered to be an act within the Company that is potentially planned, ongoing, or already committed, including:

• a criminal offense;
• an administrative offense;
• a breach of work-related duties;
• a serious violation of professional ethics standards;
• an attempt to conceal a committed or ongoing violation;
• any other legal violation that poses a threat to or infringes upon the public interest.
  
  Information about a violation is submitted in cases where the person became aware of it during the course of employment, contractual, or pre-contractual relations with the Company.

The submission of reports on violations is based on the Law on the Protection of Whistleblowers, which establishes:

• the grounds and forms of protection for persons who report violations;
• the rights and obligations of whistleblowers;
• measures for the protection, encouragement, and assistance of whistleblowers.

Directly to the Company’s Competent Persons:

• Vidas Kšanas, Director of the Safety and Security Department, email: [email protected]
• Eglė Savickė, Head of the Prevention Division, email: [email protected]
• Mindaugas Kavaliauskas, Prevention Specialist, email: [email protected]
• Reports may be submitted by email to: [email protected]
• Reports may be submitted by this form:
• Reports may also be submitted in person at Rodūnios k. 10A, Vilnius.

A person may apply directly to a competent authority if at least one of the following conditions applies:

• the violation is of significant importance to the public interest;
• immediate action is required to prevent or stop the violation due to the risk of substantial damage;
• persons in managerial positions or persons related to the Company may themselves be committing or have committed violations;
• information was submitted via the internal reporting channel but no response was received or no effective action was taken;
• there are reasonable grounds to believe that anonymity or confidentiality would not be ensured through the internal reporting channel;
• the Company does not have a functioning internal reporting channel;
• the person no longer has employment or other legal relations with the Company.

Information about a violation may be disclosed publicly only in exceptional cases where it is necessary to report an imminent threat to:

• human life or health;
• public health;
• the environment.
  
  Public disclosure is permitted where, due to time constraints, it is not possible to report the violation through other channels, or where reporting through other channels did not result in timely and appropriate action.

Under the Law on the Protection of Whistleblowers, reports may be submitted regarding:

• threats to public safety or public health, or to a person’s life or health;
• threats to the environment, including sustainability-related violations;
• obstruction of or unlawful influence on investigations conducted by law enforcement authorities or courts;
• financing of illegal activities;
• unlawful or non-transparent use of public funds or assets;
• assets acquired by unlawful means;
• concealment of the consequences of violations or obstruction of the determination of their scope;
• other violations of law.

Confidentiality is ensured for persons who submit information about violations.

The requirement to ensure confidentiality does not apply only in cases where:

• the person submitting the information requests disclosure of their identity in writing;
• knowingly false information is provided.
  
  A person who submits information in accordance with the procedure established by law and reasonably believes the information to be true shall not incur any contractual, civil, administrative or other liability.

The rights of a whistleblower, an assisting person or a person related to the violation may not be waived, restricted or denied by any agreement.

If negative measures are taken against a whistleblower or a person who submitted information, they have the right to:

• apply to a competent authority;
• apply to a court for compensation for the negative consequences suffered.
  
  A whistleblower also has the right to receive remuneration for valuable information and compensation for negative impact or potential consequences resulting from the report.