Fundamental principles of the Code of Conduct of AS “LNK Industries”

The company’s Code of Conduct is designed to develop good business practices that are based on fundamental ethical principles and support employees in taking legal and ethical decisions, at the same time providing for continuous growth and development of the company. 

The ethical principles covered by the Code of Conduct are binding to employees in their attitude towards work, in mutual communication, as well as in relations with public and non-governmental institutions, municipalities and cooperation partners.

1. Values of LNK Industries

The company has formulated 8 values that reflect LNK Industries’ understanding of ethical, honest and open business practice:

• Persistence: if we have committed to complete a task, we will deliver superior performance quality by finding solutions also in seemingly insoluble situations.

• Openness to challenges: challenges make us grow and makes us stronger – the trickier the task, the greater pleasure to solve it!

• Professional growth: we do not stop at what we have learned, we master new skills and increase existing knowledge to ensure continuous professional growth of the company and its employees. 

• Quality without compromise: quality is given top priority, yet is has value only if achieved by ethical, honest and fair conduct and in full compliance with all laws and regulations.

• Thinking out of the box: non-standard situations cannot be solved by standard methods; therefore, we are creative and always ready to act also outside the comfort zone.

• Agility: we are capable to adjust to the ever-changing business environment by maintaining our high ethical and quality standards.

• Reliability: we are a trusted partner to be relied upon the same way as we may rely upon any of our employees.

• Environment and work safety: we ensure compliance with work safety requirements and care for environmental protection, also by calling upon each of our suppliers to act responsibly and in good faith.

2. Integrity

We welcome honest and open entrepreneurship. Employees of LNK Industries at any step strictly comply with general laws and laws governing the sector as well as internal rules of procedure operational policy principles. The company regularly informs employees about changes or updates in the legal framework by calling to perform their duties in compliance with effective laws and regulations. Employees have the obligation to report on any violations detected or suspected by using internal reporting systems.

Documents, data and information that LNK Industries must prepare and submit in accordance with the internal and external rules (for example, annual report, procurement documentation, designing and construction documentation, reports to public authorities etc.), are correct and correspond to the actual situation. Employees are informed that document forfeiture or incorrect presentation of information may constitute a criminal offence. LNK Industries is legally responsible for violations of employees. 

3. Anti-corruption policy and provisions

3.1. Objective

To ensure that no employee, representative, or attorney of LNK Industries (hereinafter − Employees) or a cooperation partner performs prohibited corruptive practices.

3.2.    Prohibited practices

3.2.1. Employees and cooperation partners of LNK Industries do not give bribes, do not commit any intermediary bribery practices, do not trade in influence, and do not commit commercial bribery or prohibited acceptance of benefits.

3.2.2. Employees and cooperation partners of LNK Industries must be cautious in giving gifts to cooperation partners and must select only such gifts or offer such hospitality that a mere observer could not perceive as a bribery.

3.3. Bribe and prohibited benefit

3.3.1. A bribe implies material values, material or other benefits that are intended for a public official or any other person, so that the person takes advantage of its official position and commits or fails to commit a certain activity in the interests of the briber.

3.3.2. A prohibited benefit implies material values, material or other benefits intended for an individual, so that he or she, by using his or her powers, commits or fails to commit a certain activity in favour of the benefit giver.

3.4.    Prohibition of bribery and corruption

3.4.1. The Employee is aware that a prohibited practice implies giving, promising or offering of a bribe to a public official irrespective of whether the given, offered or promised bribe has been requested in person or via intermediary.

3.4.2. It is forbidden to accept prohibited benefits or a bribe (to give prohibited benefits) to an employee, authorised person or an official of another company (partnership) or organisation.

3.4.3. The prohibition of bribery and corruption applies to events both in Latvia and in other countries.

3.5.    Intermediary in bribery and trade in influence

3.5.1. Intermediary in bribery implies prohibited practices in the form of giving of a bribe or a promise or offer of it by the bribe giver to the bribe taker.

3.5.2. Trade in influence implies prohibited lobbying in the form of offering or giving of any material values, material or other benefits to any person that he or she, by using his or her official, professional or social status, illegally influences operations of a public official.

3.5.3. The Employee does not engage in intermediary bribery and does not support influence in trade.

3.6.    Donations to political organisations

3.6.1. LNK Industries remains politically neutral.

3.6.2. Employees of LNK Industries are aware that any direct or indirect financing of political organisations (parties) or associations of political organisations (parties) or politicians from the company’s resources is not admissible.

3.6.3. LNK Industries does not engage in transactions where cooperation partners wish to breach this statutory prohibition.

3.7.    Conflict of interest and gift policy

3.7.1. The company prevents conflicts between private interests of employees and interests of LNK Industries.

3.7.2. In order to ensure absence of conflicts, the Employee must inform the company’s management on any side work or additional employment and any cooperation with the company’s partners or competitors apart from the Employee’s duties.

3.7.3. Before conclusion of the contract the Employees involved confirm that they by themselves, their family members (spouses, parents, children, or brothers and sisters) or other relatives do not hold a position at a customer’s organisation that might influence winning of a contract of supervision of contract execution.

3.7.4. In order to get the contract awarded, no customer’s employee has been given or offered any hospitality or gifts.

3.7.5. No gifts will be given during the execution of the contract. Where upon performing his or her duties the Employee finds himself or herself in the situation of conflict of interests or his or her objectivity or neutrality may be called into question, he or she informs his or her manager on the circumstances. The immediate manager considers if further steps are necessary by consulting the respective personnel of LNK Industries.

3.8.    Reporting on bribe or prohibited benefit requests

3.8.1. Where an Employee of LNK Industries has received a direct or indirect request to give a bribe or provide a prohibited benefit, the Employee immediately or at least without any delay reports this fact to his or her direct manager or other trusted person in the company.

3.8.2. Where the Employee has failed to report the potential violation, the company does not support him or her in case any complications related to such violation arise.

3.8.3. The Employees are informed that in case of reporting they will be protected in accordance with the Whistleblowing Law.

3.9.    Informing cooperation partners and provisions of contracts

3.9.1. In provisions on cooperation with partners LNK Industries informs about the company’s Anti-Corruption Policy and Provisions by providing a copy of the provisions.

3.9.2. Where it is possible, LNK Industries in cooperation provisions with cooperation partners include the requirement to comply with the Anti-Corruption Policy and Provisions of LNK Industries, as well as to confirm that the cooperation partner complies with national anti-corruption legislation that is binding upon it.

3.9.3. In case of long-term contractual relations, once a year cooperation partners are requested to reconfirm that they comply with the Anti-Corruption Policy and Provisions.

3.9.4. Where cooperation partners request to include in contracts a requirement to comply with anti-corruption provisions of cooperation partners, LNK Industries makes sure that such provisions do not contradict the Anti-Corruption Policy and Provisions of LNK Industries by confirming this with the Management Board of LNK Industries.

3.9.5. Where the contract includes a requirement to comply with anti-corruption provision of cooperation partners, the manager of the respective project or the particular Employee is responsible for introducing the project team with the particular provisions and for supervision of compliance with the provisions.

3.10.  Information and training

3.10.1. Employees are obliged to get themselves acquainted with the Anti-Corruption Policy and Provisions, comply with them, take part in training on anti-corruption policy issues and confirm that they have understood their duties.

3.11.  Supervision and control

3.11.1. Managers (Members of the Management Board and heads of structural units) have the obligation to supervise compliance with the Anti-Corruption Policy and Provisions and to control their subordinates.

3.11.2. Managers are obliged to ensure identification and assessment of corruption risks and implementation of necessary risk mitigation measures.

3.11.3.  At least once in five years, the compliance with the Anti-Corruption Policy and Provisions is subject to a review.

4.       Free competition policy

4.1.    The objective of LNK Industries is to ensure undistorted competition.

4.1.1. Cooperation with competitors that distorts the market of goods or services supplied by LNK Industries and restricts free competition is unethical and may be subject to administrative or criminal liability.

4.1.2. LNK Industries engages in free competition with other competitors and allows customers to select the most appropriate supplier in line with the customer’s criteria.

4.2.    Provisions

4.2.1. Employees of LNK Industries do not engage in prohibited agreements with competitors on:

4.2.1.1. customer, market or market share, or service division;

4.2.1.2. pricing to customers.

4.2.2. LNK Industries does not support abuse of the dominant position by other competitors.

4.3.    Prohibited practices

4.3.1. Cartels or agreements among market participants on direct or indirect pricing, coordinated actions in tenders and sales, adjustment of price offers to ensure winning of a particular market participant or inclusion of such trade provisions that restrict competition (for example, fixing a resale price, setting a mark-up, minimum price, mandatory discounts, price range, release from liability or credit provisions).

4.3.2. The agreement among market participants on division of market or supply sources (for example, division of customer range, market or served geographical areas, exclusivity agreements, agreements on refrain from service supply or product supply to competitors’ customers or in areas or service sectors).

4.3.3. Exchange of confidential information and commercial secrets (for example, pricing or business strategy, provisions of contracts, salaries and other cost-related information).

4.4.    Precautionary measures to comply with in certain situations:

4.4.1. Meetings with competitors and negotiations.

4.4.2. Meetings with competitors are legitimate and acceptable in the following situations:

4.4.2.1. Upon request of a customer, for example, in delivery of works from one contractor to another;

4.4.2.2. In consultations organised by state or municipal institutions with the private sector, for example, on legislation issues;

4.4.2.3. Within the framework of meetings of professional non-governmental organisations (associations).

4.4.3. The aforesaid meetings are legitimate, if negotiations within the framework of them concern core issues of the meeting and do not contain signs of prohibited agreements.

4.4.4. Where the discussion issue during the meeting gives rise to a suspicion of a potential violation of free competition provisions, its participant from LNK Industries is obliged to either stop the discussion on the particular issue or immediately leave the event. This must be reported to the Member of the Management Board.

4.4.5. Confidential or commercially relevant information shall not be discussed with competitors on a private basis to avoid a situation where a competitor adjusts its price policy.

4.4.6. Know-how and intellectual property. Where exchange of know-how or intellectual property takes place only among certain market participants, there is a potential competition violation risk.

4.5.    Duties

4.5.1. The Employee has the duty to consult the direct manger before staring negotiations or other cooperation-aimed measures with a competing market participant.

4.5.2. The Employee must immediately inform the direct manager or the Member of Management Board if the Employee sees a potential violation of competition or applicable legislation.

5. Confidentiality and conflicts of interest

The company avoids conflicts between private interests of employees and interests of LNK Industries. To ensure this, employees must inform the company’s management on additional employment and cooperation of any kind with partners or competitors of the company, that fall outside direct duties of employees.

Employees must strictly comply with confidentiality requirements set by the company, particularly regarding external and internal information obtained during preparation of procurements, the company’s financial situation and other financial data related to the company’s operations, personal data processed by the company and other information the unauthorised disclosure of which could cause any harm to the company, subject of the confidential information or any third party.  

Where an employee obtains information on committed or potential violations of confidentiality provisions or conflict of interest, the employee must report this to his or her superior or the company’s management. 

6. Data protection

LNK Industries ensures personal data protection in compliance with effective laws of the Republic of Latvia. The company has developed a publicly available Privacy Policy, as well as internal rules on personal data protection that are binding upon all employees of the company. Any data subject may address personal data protection issues to the Data Protection Officer of LNK Industries.

7. Use of resources to process information

A crucial resource of LNK Industries is our IT infrastructure. Business continuity is ensured by flawless functioning of computer systems, we therefore abide by the following principles:

• No actions are permitted which impair the operational safety and reliability of the company’s IT infrastructure and thus result in legal, financial and intangible damage for the company;

• The company’s IT systems (these include e-mails) may never be used for aggressive, offensive, violent purposes, including for creation, display, storage or transmission of pornographic, racist or morally offensive content;

• The necessary care must be exercised when using the Internet;

• LNK Industries uses only legally developed and purchased software. Employees of the company are aware that illegal use of software may result in severe legal consequences both for the employee at fault and the company.   

8. Occupational health and safety

We care for occupational health and safety of our employees. The company’s ability to ensure the compliance with occupational health and safety requirements is proven by the certificate on conformity of operations to requirements of standard ISO 45001:20018 “Occupational health and safety management systems” granted to LNK Industries. At LNK Industries, no employee of the company has ever suffered in a serious accident: work safety is one of the company’s top priorities. LNK Industries provides employees with health insurance policies and statutory health examinations, as well as takes care of a pleasant, comfortable and ergonomic work environment for employees.  

9. Social responsibility

For LNK Industries, corporate social responsibility means responsible and sustainable entrepreneurship, care for the environment, modern and development-oriented work environment and contribution to public support measures. Asserting itself as a socially responsible company, LNK Industries implements the following measures:

• Waste separation at all construction objects of the company, including correct utilisation of dangerous waste, and waste separation at the company’s office (paper, glass, plastic, toners, batteries);

• Development of environment protection programmes both for the company as a whole and each construction object individually;

• Development of recommendations for electricity saving and economic driving, communicated to all employees of the company;

• Development and implementation of detailed employee training programme that ensures professional and personal growth of employees (the programme is updated annually by taking into account needs of employees and the company’s development context);

• Implemented internal training in environment protection, energy management, fire safety, personal data protection, competition law etc.;

• The company is a member of the Latvian Chamber of Commerce and Industry (LTRK), the Latvian Employers Confederation (LDDK) and the Partnership of Latvian Constructors, and its representatives take active part in initiatives of these organisations, including by getting involved in taking responsible decisions regarding regulatory framework for the sector;

• The company has signed the general agreement of the construction sector (a general agreement is a collective agreement between employers and employee of the construction sector that provides for the minimum wage for those working in the construction sector);

• The company is a longstanding supporter of the Children’s Foundation of Latvia and the Latvian National Opera and Ballet, gives donations to the association “Basketbola klubs Jēkabpils”, the foundation “Fund of Science”, the association “Charity.lv” and other public benefit organisations.

10. Cooperation of LNK Industries with suppliers

LNK Industries expects its suppliers (namely, manufacturers, suppliers and subcontractors) to have similar values and understanding of ethical, honest and open entrepreneurship and calls upon suppliers to comply with effective laws, including in the area of anti-corruption, taxes, data protection and work safety, as well as to take care for the environment and well-being of their employees. LNK Industries evaluates performance of each of its suppliers and attitude towards good business practices and takes these evaluations into account when planning further cooperation.  

11. Other internal rules

In addition to the Code of Conduct, LNK Industries has developed and presented to all employees of the company the following documents:

• Privacy Policy;
• Personal data protection regulation;
• Internal data processing protection regulations (in video surveillance);
• Description of the whistleblowing system;
• Procedure for cooperation with competitors / acceptance of the total price offer;
• Information technology security policy;
• Information system continuity and renewal plan,

as well as other internal regulations governing work security, fire safety, environment protection etc. in compliance with external legislation binding upon the sector.   

12. Implementation and performance of the Code of Conduct

The Code of Conduct of LNK Industries is an integral part of documents governing operations of the company and thus it is binding upon all employees of the company. Senior and middle managers by their position and behaviour set an example for employees, as well as consult employees on ethically correct behaviour in uncertain situations.   

The company’s employees are aware that the company’s reputation is built by all employees and each of them is identified with the company.

The company’s management discusses the Code of Conduct at least once a year and evaluates the need to make changes or additions. Employees are informed about changes in the Code of Conduct at the general meeting or by sending information to e-mail addresses of employees. Employees are welcome to participate in improvement and promotion of the Code of Conduct.