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Ensuring staff credibility
Acting in accordance with the provisions on staff credibility of the Law on Prevention of Corruption and in order to assess whether a person is suitable for a specific position, Lietuvos bankas, before appointing them to a position, sends a written request to the Special Investigation Service for collection and provision of information about the person.
Statistical information: 82 requests for candidates were sent in 2021, 133 in 2022 and 102 in 2023.
Likelihood of corruption
Taking into account that a public sector entity may, but is not obliged to, implement this corruption prevention measure at its own discretion under Article 10 of the Law on Prevention of Corruption, Lietuvos bankas currently does not determine the likelihood of corruption.
Corruption risk analysis
In accordance with Article 6 of the Law on Prevention of Corruption, the Special Investigation Service analyses corruption risks according to the procedure laid down by its Director.
The Special Investigation Service notifies in writing the public sector entity whose activities are to be analysed of the decision taken to conduct a corruption risk analysis.
After conducting the corruption risk analysis, the Special Investigation Service submits a draft conclusion of corruption risk analysis to the public sector entity containing information on the identified corruption risk and/or its factors as well as recommendatory proposals to mitigate the identified corruption risk and/or eliminate its factors.
If a public sector entity receives the conclusion of corruption risk analysis from the Special Investigation Service containing the identified corruption risk and/or its factors as well as recommendatory proposals to mitigate the identified corruption risk and/or eliminate its factors, it publishes, within three months from the date of receipt of the conclusion, on its website the information on how the proposals contained in the conclusion are or will be implemented and provides the Special Investigation Service with the link to this information.
Lietuvos bankas has not received any information from the Special Investigation Service on the decisions taken to carry out a corruption risk analysis in the areas of activities of Lietuvos bankas.
Anti-corruption assessment of draft legislation
According to Article 8 of the Law on Prevention of Corruption, a public administration entity preparing a draft regulatory legal act must carry out an anti-corruption assessment of the draft legal act in accordance with the procedure laid down by the Government. In accordance with paragraph 33.3 of the Description of the Procedure for Drafting Legal Acts at Lietuvos bankas approved by Order No V 2015/(1.7-260603)-02-252 of the Chairman of the Board of Lietuvos bankas of 31 December 2015 on the approval of the description of the procedure for drafting legal acts at Lietuvos bankas, if the legal act will be made available for comment to the public and/or supervised financial market participants and other interested institutions and it is intended to regulate public relations specified in Article 8(1) of the Law on Prevention of Corruption or the internal administrative legal act is intended to regulate public procurement, procedure for the management, use and disposal of assets of Lietuvos bankas, the draft legal act must be submitted to the Legal Division of the Strategy and Governance Department of Lietuvos bankas for an anti-corruption assessment.
The anti-corruption assessment reports drawn up by Lietuvos bankas for draft legal acts are published in the information system of legal acts and draft legal acts of the Seimas of the Republic of Lithuania together with the respective drafts, as their annexes.
Corruption resilience level
In accordance with Article 12 of the Law on Prevention of Corruption, the corruption resilience level is determined by assessing to what extent and which measures have been put in place by the public sector entity to create an anti-corruption environment, quality and practical applicability of these measures and outcomes of their implementation. These elements of implementation of measures for the creation of anti-corruption environment are used to calculate the corruption resilience level of the public sector entity which may range from very low to very high on a predefined scale.
The results of the corruption resilience level assessment are published on the website of the public sector entity.
The methodology for the corruption resilience level assessment is approved by the Government of the Republic of Lithuania.
Lietuvos bankas will carry out the corruption resilience level assessment after the Government of the Republic of Lithuania approves the methodology for the corruption resilience level assessment.
Offences of corrupt nature
In accordance with Article 23 of the Law on Prevention of Corruption, public sector entities publish on their website anonymised information on the offences of corrupt nature detected by them in the last three years, their nature and number, actions taken to investigate them and legal or other sanctions imposed to remedy the consequences of such offences and prevent them in future.
In the last three years, no offences of corrupt nature were detected in Lietuvos bankas.
Documents for planning corruption prevention
According to Article 7 of the Law on Prevention of Corruption, action plans for the area of activities and corruption prevention action plans of a public sector entity may be drawn up by decision of the head of the public sector entity, but they are not obligatory. Currently, no decision by the Chairman of the Board of Lietuvos bankas has been adopted to drawn up the relevant documents for planning corruption prevention.
Where and how to report corruption
Article 9 of the Law on Prevention of Corruption lays down an obligation for an employee of a public sector entity to report a criminal offence of corrupt nature known to them to the Prosecutor’s Office of the Republic of Lithuania, Special Investigation Service or another pre-trial investigation institution, except for an act which may have been committed, is being committed or is about to be committed by their close relatives or family members (the terms close relatives and family members are understood within the meaning of Chapter II of the Code of Criminal Procedure of the Republic of Lithuania), if they have any information which allows them to reasonably believe that the act has been committed, is being committed or is about to be committed, and if there are no restrictions on the disclosure of information to be reported laid down by law.
The report of a criminal offence of corrupt nature known to the employee of the public sector entity must be made to the designated entities as soon as possible after the moment of becoming aware of the criminal offence of corrupt nature.
Persons reporting criminal acts of corrupt nature may be subject to assistance, protection and incentive measures in accordance with the Republic of Lithuania Law on the Protection of Whistleblowers and other legal acts.
There are various ways of reporting corruption to the Special Investigation Service available on the website of the Special Investigation Service.
There are various ways of reporting corruption to the Prosecutor’s Office of the Republic of Lithuania available on the website of the Prosecutor’s Office of the Republic of Lithuania.
Ethical standards
Together with the European Central Bank and central banks of all the Member States of the European Union, we are part of the European System of Central Banks (ESCB). By joining the euro area, Lithuania also became a member of the Single Supervisory Mechanism of the banking union.
In the context of tasks entrusted to the Eurosystem, the national central banks are committed to the principles of independence, accountability, transparency and highest standards of professional ethics, which is why the Governing Council of the European Central Bank has adopted the following guidelines:
- Guideline (EU) 2021/2253 of the European Central Bank of 2 November 2021 laying down the principles of the Eurosystem Ethics Framework (ECB/2021/49) (recast)
- Guideline (EU) 2021/2256 of the European Central Bank of 2 November 2021 laying down the principles of the Ethics Framework for the Single Supervisory Mechanism (ECB/2021/50) (recast)
To ensure proper implementation of these guidelines at Lietuvos bankas, the Code of Ethics of the Employees of the Bank of Lithuania was approved by Resolution No 03-77 of the Board of Lietuvos bankas of 15 May 2014 on the code of ethics of the employees of the Bank of Lithuania. In addition, employees of Lietuvos bankas who have access to sensitive market information due to their relevant position at Lietuvos bankas must comply with the Rules on Personal Financial Transactions of Employees of the Bank of Lithuania.
Employees of Lietuvos bankas who are also members of a high-level body of the European Central Bank are required to comply with the Code of Conduct for high-level ECB officials.
Adjustment of interests
Everyone has legitimate interests and may find themselves in a situation of a conflict of interest and the employees working at Lietuvos bankas are no exception. To manage conflict of interest risks, the following principles apply at Lietuvos bankas:
- proper declaration of private interests;
- abstention from any official duties involving private interests;
- measures to manage and eliminate conflicts of interest are taken not only by the person exposed to the conflict of interest but also by their supervisors (exclusion from addressing the issue, restriction of access to the relevant information, reassignment of official duties and/or functions);
- managing revolving door risks.
According to the Republic of Lithuania Law on the Adjustment of Public and Private Interests, the following persons employed by Lietuvos bankas must submit a declaration of private interests by electronic means in accordance with the procedure laid down by the Chief Official Ethics Commission (Article 2(5) and Article 4(3)(9)):
- employees of Lietuvos bankas with public administration powers (financial market supervision, out-of-court settlement of disputes between consumers and financial market participants as well as other public administration functions);
- members of procurement commissions, employees of Lietuvos bankas appointed to carry out simplified procurement procedures, experts participating in procurement procedures, originators of public procurement or concession.
Article 22(2) of the Law on the Adjustment of Public and Private Interests states that institutions must approve a list of positions for which declarations of private interests are required.
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