Anti-Corruption Policy

LINEV Systems EU UAB applies the Anti-Corruption Policy in all business activities, including the design, development, production, installation, and maintenance of instruments and equipment based on X-ray, ionizing, and electromagnetic radiation technologies.

Key Objectives of the Anti-Corruption Policy

Reduce the risk of corruption in company operations and manage it effectively.
Ensure the proper and timely implementation of corruption prevention measures as required by law and other regulations.
Establish behavioral requirements for employees in the area of corruption prevention and ensure these requirements become internalized and voluntarily adhered to, not only by employees but also by the company’s stakeholders.

Principles of the Anti-Corruption Policy

Prohibition of Bribery and Corruption

The company does not tolerate any forms of corruption, regardless of the degree or extent of involvement. Any employee who engages in corrupt activities, regardless of their position, responsibilities, or contributions to the company, will be held accountable under applicable legal provisions.

Bribery and Extortion

All employees must resist any persuasion to give or accept a bribe. Employees must reject any requests from clients or business partners for bribes or any other form of valuable compensation.

Facilitation Payments

Employees are strictly prohibited from offering or accepting facilitation payments, which are payments made to encourage or expedite routine administrative processes.

Legality

Anti-corruption management system measures must comply with the laws of the Republic of Lithuania and other applicable international anti-corruption regulations.

Conflict of Interest

The company avoids conflicts of interest or situations that may contradict an employee’s professional responsibilities. Employees are expected to act in the best interests of LINEV Systems EU UAB and make decisions uninfluenced by personal interests.

Employee Involvement

Employees are continuously informed about the company’s Anti-Corruption Policy and are involved in implementing anti-corruption control measures.

Adequacy of Anti-Corruption Control Measures

Anti-corruption control measures are designed and implemented according to the level of identified corruption risks.

Effectiveness of Anti-Corruption Measures

The company prioritizes anti-corruption control measures that are simple to implement, provide significant benefits, and do not become a burden to the company.

Continuous Monitoring, Oversight, and Improvement

To continuously improve the anti-corruption management system, the company regularly monitors the implementation of anti-corruption measures and evaluates the effectiveness of its Anti-Corruption Policy.

Responsibilities and Authorities
The primary entities responsible for forming and implementing the company’s anti-corruption management system are the Company Director and the Employee Responsible for Corruption Prevention (Compliance Officer).

The Director may allocate additional human resources to support the implementation of the anti-corruption management system.

The Director’s Responsibilities and Authority in Implementing the Anti-Corruption Management System

Ensures the implementation of the anti-corruption management system in the company and its compliance with the LST ISO 37001:2017 standard.
Allocates sufficient resources and assigns appropriate functions necessary for the effective operation of the anti-corruption management system.
Appoints an employee responsible for corruption prevention, whose primary duty is to oversee the implementation of the company’s anti-corruption management system. The responsibilities of this role are detailed in the company’s internal procedures and documents.
May appoint additional employees responsible for specific anti-corruption compliance functions and assign them defined tasks and responsibilities.
Ensures that the company’s strategy and Anti-Corruption Policy are aligned.
Approves the company’s Anti-Corruption Policy.
Conducts periodic reviews and evaluations of the anti-corruption management system.
Oversees the implementation and effectiveness of the company’s anti-corruption management system.

All employees of the company are personally responsible for understanding, complying with, and implementing the anti-corruption management system requirements related to their duties.

Reporting Violations of the Anti-Corruption Policy

Employees are encouraged to report any observed or suspected violations of the Anti-Corruption Policy, conflicts of interest, or potential corruption cases. Reports can be submitted via email to korupcija@duomenuperkelimui.eu. The company is committed to maintaining the confidentiality of whistleblowers and will take all possible measures to ensure that individuals who report suspected violations of the Anti-Corruption Policy, corruption cases, or conflicts of interest do not suffer negative consequences as a result. Cases of Anti-Corruption Policy violations may be disclosed through internal communication channels, provided that such disclosures do not violate data protection regulations.

Legal Responsibility

Violations of the Anti-Corruption Policy may be considered a serious breach of work duties and may result in consequences as specified by Lithuanian law. If a violation of the Anti-Corruption Policy constitutes a criminal offense, it will be reported to the relevant authorities, and legal action may be taken.

Final Provisions

All current and newly hired employees must familiarize themselves with and comply with the Anti-Corruption Policy.
All interested parties must also be informed about the company’s Anti-Corruption Policy.
The Anti-Corruption Policy is publicly available.
The company’s Director approves and authorizes any amendments to the Anti-Corruption Policy.