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Whistleblowing Policy

  1. INTRODUCTION
    1. The Whistleblowing Policy, referred to as the Policy herein, establishes the processes for reporting suspected misconduct, violations of legal responsibilities, unethical behavior, intentional concealment, or inaction at Longavia. This Policy complies with the EU Whistleblower Directive (EU Directive 2019/1937) and applicable legal acts, including but not limited to the Lithuanian Law No XIII-804 on Whistleblower Protection and other relevant legislation. It commits to creating a transparent and ethical organizational culture and specifically addresses risks pertinent to the transportation/logistics/freight forwarding sector.
  1. PURPOSE
    1. Longavia is committed to maintaining high standards of ethics and integrity. Whistleblowers are encouraged to report any suspected wrongdoing through designated channels, and they will be protected from retaliation. This protection undertaking extends to all individuals connected with the Whistleblower and adheres strictly to Lithuanian laws and the EU Directive.
    2. The purpose of this Policy is to:
      1. Foster a culture that encourages employees and stakeholders to report any concerns they may have.
      2. Ensure reports are handled confidentially and investigated appropriately.
      3. Protect whistleblowers from retaliation.
      4. Comply with EU Whistleblowing Directive and applicable national laws.
      5. Address and mitigate sector-specific risks.
  1. SCOPE
    1. This Policy applies to:
      1. Employees at all levels, including senior management and entry-level positions.
      2. External stakeholders, contractors, suppliers, and clients.
      3. Consultants, volunteers, interns, casual workers, and agency workers.
      4. Voluntary workers, members of the board, shareholders, and individuals providing assistance to whistleblowers.
  1. DEFINITIONS
    1. “Whistleblowing” means the act of reporting suspected wrongdoing within the organization..
    2. “Whistleblower means an individual who reports misconduct under this policy..
    3. “General Interest” means information disclosed that pertains to public concern and extends protection beyond simple breaches of national or EU law, encompassing a wider range of disclosures.
  1. RESPONSIBILITIES
    1. All individuals within Longavia have a role to play in maintaining an ethical and transparent organizational culture. 
    2. It is the duty of employees to report any observed or suspected unethical practices in earnest through the specified reporting channels. This means that employees must provide accurate and honest information based on their observations or knowledge, ensuring that the integrity of the reporting process is maintained.
    3. Managers and supervisors carry an additional responsibility by promoting this Policy within their teams. They are tasked with creating an environment where employees feel safe and confident to report concerns without fearing retaliation. This involves actively communicating the importance of this Policy, providing training, and leading by example. Managers and supervisors must handle any received reports with utmost discretion and ensure they are escalated to the Compliance Officer for appropriate investigation. Their role is crucial in fostering an open culture where employees' concerns are taken seriously and addressed promptly.
    4. The Compliance Officer has a vital role in the implementation and oversight of the whistleblowing process. Officer’s responsibilities include receiving and acknowledging reports, conducting thorough investigations, and managing each case with the highest standards of confidentiality. The Compliance Officer must ensure that Whistleblowers are provided with the necessary support, including protection from any form of retaliation. They are also responsible for maintaining accurate records of all reported cases, from initial receipt to final resolution. This record-keeping is essential for ensuring transparency, accountability, and continuous improvement of the Whistleblowing process. By effectively managing reports and providing updates to the senior management, the Compliance Officer ensures that Longavia maintains its commitment to ethical practices and regulatory compliance.
  1. REPORTING PROCEDURE
    1. The reporting procedure ensures that all concerns about wrongdoing are reported securely, confidentially, and investigated appropriately. Here are the detailed steps for reporting and handling a whistleblower report:
    2. Channels for Reporting:
      1. Email: please send a report to the dedicated email address: whistleblower@longavia.lt.
      2. Post: please send an anonymous report via mail to:: Vilties g. 11, Kuprioniškių k., LT-13279 Vilniaus r., Attention: Compliance Officer, UAB Longavia.
    3. Anonymity: Reports can be made anonymously via email or post to encourage openness and protect the whistleblower’s identity. Secure channels prevent tracking of personal information or IP addresses.
    4. Procedure for Handling Reports About Managers or Supervisors. If the report concerns a manager or supervisor, it will be directed to a higher authority or a designated independent body to ensure an unbiased investigation.
    5. Process Overview:
      1. Receipt of Report. When a report is received, whether through the dedicated email address or anonymously via post, the Compliance Officer will log the receipt of the report. A confirmation of receipt will be sent to the Whistleblower within 7 days if contact information is provided, ensuring that the Whistleblower is aware that their report has been received.
      2. Preliminary Review: The Compliance Officer will conduct a preliminary review of the report to evaluate its validity. This review will be completed within 1 month from the date of receipt. The Whistleblower will be kept informed of the progress during this period if they have provided contact information.
      3. Investigation: If the preliminary review confirms that the report is valid, a detailed investigation will be initiated. The Compliance Officer will gather all relevant information and evidence. Interviews with involved parties may be conducted if necessary. The investigation will be conducted thoroughly to ensure all aspects of the report are considered. The identity of the whistleblower will be protected and kept confidential, accessible only to those directly involved in the investigation.
      4. Updates and Communication: Regular updates on the status of the investigation will be provided to the Whistleblower, as long as this does not compromise the process or the anonymity requested by the Whistleblower.
      5. Conclusion and Action. Upon conclusion of the investigation, appropriate actions will be determined based on the findings. Possible actions may include disciplinary measures against individuals involved in wrongdoing, changes in Longavia policies or procedures, or referrals to law enforcement or regulatory bodies for severe breaches. The case will be officially closed, and a final report summarizing the investigation and its outcomes will be documented.
      6. Record-Keeping. The Compliance Officer will maintain accurate records of all received reports, actions taken, and the final outcomes. These records will be stored in compliance with data protection regulations and will be used to ensure transparency, accountability, and continuous improvement of the whistleblowing process.
    6. By following these detailed steps, Longavia ensures that all Whistleblower reports are handled appropriately, maintaining the confidentiality and integrity of the process while fostering a culture of transparency and ethical behavior.
    7. Escalation Procedure. In cases where the severity or complexity of a reported concern necessitates involvement from senior management, Longavia shall implement clear escalation protocols. These protocols outline the steps for escalating reports to higher seniority level, detailing the information to be provided, the decision-making process, and the responsibilities of senior stakeholders in overseeing critical investigations or resolution processes. Senior management shall actively engage in monitoring and addressing escalated concerns to ensure timely and effective responses.
    8. The duration of an investigation depends on the complexity of the report. A confirmation of the report’s receipt will be provided within 7 days, preliminary review will be conducted within 1 month and conclusion will be delivered within 3 months, ensuring thoroughness and accuracy while respecting legal timelines.
  1. CONFIDENTIALITY
    1. Longavia is committed to safeguarding the anonymity of whistleblowers throughout the entire reporting and investigative process. Whistleblowers' identities will be kept confidential and protected from disclosure to maintain their safety and encourage open reporting of concerns. Anonymity is a fundamental aspect of our Policy to ensure transparency, trust, and the protection of individuals who speak up against wrongdoing within the organization.
    2. Longavia implements robust measures to ensure the confidentiality and protection of Whistleblowers' identities and report details.
    3. Access to whistleblower information shall be restricted to authorized personnel directly involved in the investigative processes, maintaining the highest level of confidentiality and preventing unauthorized disclosure of sensitive information.
    4. Retention of personal information shall not exceed three years unless its preservation is deemed unnecessary for issue resolution, requiring immediate deletion in accordance with applicable data protection laws. 
  1. PROHIBITION OF FALSE REPORTING AND CONSEQUENCES
    1. False reporting undermines the integrity of the whistleblowing process and can have detrimental effects on Longavia. Therefore, Longavia strictly prohibits any form of false or malicious reporting. 
    2. Individuals are expected to provide truthful and accurate information when reporting concerns under this Whistleblowing Policy.
    3. Consequences for engaging in false reporting may include disciplinary action, up to and including termination of employment, legal liabilities, or other appropriate measures in accordance with Longavia's policies and applicable laws. 
    4. It is imperative that all reports submitted are done so in good faith and with genuine concerns to maintain the effectiveness and trustworthiness of the whistleblowing system.
  1. PROTECTIONS FOR WHISTLEBLOWERS
    1. Whistleblowers are protected from retaliation, including termination, demotion, harassment, or discrimination under the Lithuanian Law on Whistleblower Protection and EU Directive. This protection extends to individuals providing assistance to Whistleblowers or entities related to them.
    2. Longavia strictly prohibits any form of reprisal, retaliation, or adverse action against individuals who report suspected wrongdoing in good faith under this Policy. 
    3. Individuals involved in retaliatory actions will face disciplinary measures, potentially leading to termination of employment or legal repercussions, as stipulated by relevant laws. 
    4. Whistleblowers and individuals providing assistance to whistleblowers are entitled to protection from retaliation, ensuring their safety and encouraging a culture of transparency and accountability within the organization.
  1. OUTCOMES OF INVESTIGATIONS
    1. 10.1.Upon conclusion of an investigation under this Whistleblowing Policy, potential outcomes may encompass:
      1. Implementation of disciplinary measures against individuals implicated in the reported misconduct, in accordance with the applicable laws, Longavia’s policies and relevant employment regulations.
      2. Implementation of procedural modifications aimed at mitigating the recurrence of wrongdoing patterns or gaps identified through the investigation process.
      3. Referral of substantiated claims of severe breaches to pertinent law enforcement agencies or regulatory bodies for further examination, in adherence to statutory obligations and industry protocols.
      4. Consideration and implementation of compensatory measures, as prescribed by EU laws, to address any adverse impact on affected individuals resulting from the reported misconduct or organizational deficiencies identified during the investigative process.
  1. COMMUNICATION AND TRAINING
    1. 11.1.Employees and stakeholders will be informed about this Policy through regular training sessions and internal communication channels to ensure awareness and understanding. 
    2. 11.2.Longavia shall conduct comprehensive training sessions on whistleblowing policies and procedures for all employees, stakeholders, and relevant parties on a regular basis. These training programs will cover topics such as whistleblower rights, reporting procedures, confidentiality measures, and non-retaliation protections. 
    3. 11.3.Longavia must ensure that all personnel are aware of their rights and obligations under this Policy and relevant legislation.
    4. 11.4.Longavia shall ensure that all personnel are adequately informed about their roles and responsibilities under this Policy, promoting a culture of ethical behavior, compliance, and prompt reporting of concerns.
  1. SECTOR-SPECIFIC RISKS AND MITIGATION STRATEGIES
    1. 12.1.Potential risks within the Longavia operating in the Transportation/Logistics/Freight Forwarding sector, encompass various areas such as safety violations, regulatory breaches, financial irregularities, and human rights violations. 
    2. 12.2.Longavia undertakes following mitigation approaches including regular training, detailed reporting guidelines, establishment of expert committees, implementation of stringent audit processes, and the promotion of a culture centered on safety, compliance, and ethical behavior to address these risks effectively:
      1. 12.2.1.Regular training sessions: Longavia organizes specialized training sessions focusing on the identified risk areas to underscore the importance of reporting and adherence to compliance standards.
      2. 12.2.2.Detailed guidelines: Longavia develops comprehensive guidelines for handling sector-specific reports to ensure timely and effective responses to reported concerns.
      3. 12.2.3.Sector-specific Compliance Officer/committee: Longavia Compliance Officer (or committee in the future) shall be experts in transportation and logistics to review and take action on reports pertinent to the sector.
      4. 12.2.4.Stringent audit and monitoring processes: Longavia implements rigorous audit and develops monitoring mechanisms to proactively detect and address issues within the sector.
      5. 12.2.5.Foster a culture of safety, compliance, and ethical conduct: Longavia cultivates an organizational ethos that prioritizes safety, compliance with regulations, and ethical practices throughout all levels of the organization.
    3. 12.3.Longavia recognizes the importance of feedback from Whistleblowers to assess the effectiveness and responsiveness of the Whistleblowing process. Whistleblowers shall have the opportunity to provide feedback on their experience with the reporting process, including suggestions for improvement or areas of concern. Feedback received will be carefully reviewed, and appropriate measures will be implemented to address any identified shortcomings or enhance the overall Whistleblower experience. This feedback loop demonstrates Longavia's commitment to continuous improvement and the well-being of individuals reporting suspected wrongdoing within the organization.
  1. MISCELLANEOUS
    1. 13.1.By adhering to this Policy, Longavia reinforces its commitment to ethical behavior and compliance with legal obligations, fostering a culture of integrity and accountability within the company. This Policy also reflects the Longavia’s strict commitment to the enhanced protections provided under the EU Whistleblowing Directive as well as Lithuanian law, specifically addressing the unique risks associated with the transportation/logistics/freight forwarding sector.
    2. 13.2.Longavia undertakes to ensure alignment of this Policy with all other corporate policies (e.g., those related to anti-bribery, health, and safety, etc.) and regularly review and update the Policy to align with requirements of the applicable law, including Lithuanian Law on Whistleblower Protection and the EU Directive.
    3. 13.3.Longavia acknowledges the dynamic nature of whistleblowing regulations and best practices and commits to conducting regular reviews and updates of this Policy. Compliance Officer shall conduct periodic assessments of the Policy to align with changes in legislation, industry standards, and organizational requirements. 
    4. 13.4.Updates to the Policy shall be communicated to all relevant parties, and any necessary revisions will be promptly implemented to enhance the effectiveness and compliance of the whistleblowing framework.
    5. 13.5.This Whistleblowing Policy has been approved by the CEO. Any amendments to the Policy will require approval of Longavia’s CEO.