PZU korruptsioonivastane programm

General Provisions 

1. The purpose of the Anti-Corruption Program (hereinafter referred to as the “Program”) of AB “Lietuvos draudimas” (hereinafter referred to as the “Company,” including its Estonian branch) is to enhance the Company’s reputation by establishing key standards of conduct to prevent corruption risks. 
2. Among others, the Company’s authorized representatives (including insurance agents) and business partners are required to comply with the principles set out in the Program. 

Definitions 

1. The terms and abbreviations used in the Program have the following meanings:
   1.1 Corruption risk factors – situations that facilitate or may facilitate an environment conducive to corrupt practices; 
   1.2 Facilitation payment – a form of corruption that involves making small and unofficial payments or other types of benefits to expedite routine actions to which the payer is legally entitled; 
   1.3 Corruption – the direct or indirect solicitation, acceptance, offering, or promise of any undue material or personal benefit in exchange for an action or omission related to duties performed within the Company; 
   1.4 Material benefit – any tangible benefit given or received by an employee in connection with their position or duties, excluding salary and other legally recognized compensation, as well as customary souvenirs that are not subject to personal income tax; 
   1.5 Personal benefit – any intangible benefit that enhances the position of an employee, their relatives, or individuals or organizations with whom they have or have had close professional, business, or personal relations; 
   1.6 Bribery – a form of corruption involving the offering or acceptance of any of the following: a) gifts, loans, payments, rewards; b) other material benefits; c) other personal benefits; – to or from another person as an incentive for dishonest or illegal conduct or a breach of trust in the performance of the Company’s tasks. 
   1.7 Relative – primarily a spouse, ascendant or descendant relative, sibling, in-law in the same lineage or degree, an adopted person and their spouse, or partner; 
   1.8 Business partner – a natural or legal person or an organizational unit without legal personality with whom the Company has a business relationship, primarily involving the supply of goods or the provision of services, excluding services provided by the Company in the context of insurance activities. 

Anti-Corruption Rules and Sanctions 

1. Corruption may be subject to civil or criminal penalties. The Company, its authorized representatives (including insurance agents), and business partners must act honestly and in compliance with legislation, actively fighting against any form of corruption. 
2. In fulfilling business-related obligations, individuals must act ethically and legally, avoiding corrupt practices (particularly by refraining from making decisions based on corrupt customs) and mitigating factors that increase corruption risks. 
3. It is prohibited to offer, promise, give, or demand material or personal benefits to manipulate decisions in proceedings, in particular: 
   a) engaging in facilitation payments;
   b) favouring individuals in hiring or promotions;
   c) using forged, altered, or manipulated documents or making inaccurate (unreliable or misleading) entries in accounting records;
   d) proposing or agreeing to pay business partners or clients amounts other than those permitted under contractual agreements;
   e) offering material or personal benefits to officials, employees of business partners, their family members, or relatives.

Corruption Risk Management 

1. Corruption risks are monitored and managed through the following actions: 
   1.1 Establishing clear rules for employee recruitment, promotion, and remuneration; 
   1.2 Transparent allocation of work tasks and authorities in job descriptions; 
   1.3 Detailed internal regulations on the acceptance and offering of gifts and benefits, conflict of interest management, control of accounting entries, and execution of sponsorship and prevention activities. 

Reporting Corruption 

1. Any suspicions or incidents that may involve breaches of the provisions of this Program must be reported to the Company.
2. Reports, including anonymous ones, should be submitted through the designated channel for reporting deviations and incidents: https://pzu.ee/rikkumisest-teavitamine/ 
3. It is prohibited to discriminate against individuals who submit reports as referred to in point 1. 

Measures to Limit Corruption Risks 

1. When entering into contracts with business partners and clients, applicable legal provisions and good business practices must be followed, including: 
   1.1 Adhering to business ethics principles to ensure transparent business relations; 
   1.2 Avoiding situations that may appear inappropriate or inconsistent with legal requirements. 
2. The process of selecting business partners must be transparent. Decisions on cooperation with business partners must be based on objective criteria. 
3. Procurement processes must be conducted in a manner that ensures compliance with the principles of fair competition. 

Measures to Limit Corruption Risks in HR Policy 

1. Employee recruitment and remuneration must be transparent and based on objective criteria. 
2. Personnel management, including recruitment, performance evaluation, promotion, career development, and training, must ensure equal opportunities for employees. 
3. The bonus system used to reward employees must not encourage illegal or unethical behaviour. 
4. Employees must not be penalized for refusing to offer or accept bribes or facilitation payments. 

Social Assistance and Sponsorship 

1. Donations, grants, support for foundations, community centres, associations, and other entities, as well as sponsorship activities (including prevention activities), must comply with applicable laws and other legal regulations. 
2. The activities referred to in point 1 must be documented to allow for verification of decision-making details if necessary. 
3. The provision of free benefits to an interested party or a third party must not be a condition for concluding a business transaction. 
4. Grants, donations, and other social assistance benefits may only be provided to duly registered entities, including charitable organizations, in accordance with applicable legal provisions. 

Accounting Records 

1. Accounting records must be maintained reliably, accurately, and in a verifiable manner. 
2. Measures are implemented to prevent, in particular: 
   2.1 The registration of transactions that do not reflect the actual business situation; 
   2.2 The recording of expenses based on incomplete or inaccurate documents; 
   2.3 The approval of received documents and calculations without proper authorization;
   2.4 The use of falsified documents;
   2.5 Actions that violate established rules and deadlines for the archiving and destruction of accounting records, ensuring their lawful availability. 

Conflicts of Interest 

1. Situations that may lead to conflicts of interest must be avoided, particularly employment in other entities and companies if such positions may negatively affect the objectivity of assessments, decision-making, or corruption risks.