Code of Ethics of the Employees of the Bank of Lithuania

APPROVED by Resolution No 03-77 of the Board of the Bank of Lithuania of 15 May 2014 (version of Resolution No 03-48 of the Board of the Bank of Lithuania of 14 April 2016) THE CODE OF ETHICS OF THE EMPLOYEES OF THE BANK OF LITHUANIA CHAPTER I GENERAL PROVISIONS The Code of Ethics of the Employees of the Bank of Lithuania (hereinafter — Code) defines the principles of conduct to be observed by the Chair of the Board of the Bank of Lithuania (hereinafter — the Bank), the Deputies, Board Members and other employees of the Bank of Lithuania (hereinafter — Employees). During and after working hours at the Bank, Employees shall comply with the provisions of the Code and act in accordance with generally accepted rules of conduct, so as not to discredit the reputation of the Bank and the authority of the Employee. General principles of conduct established in the Code, provisions on security of information, as well as requirements laid down in paragraphs 24 and 25 of the Code shall apply to persons accepted for an internship at the Bank. The principles of conduct laid down in the Code have been established with a view to providing a creative and benevolent working environment, developing respect for co-workers and other persons, ensuring the independence and good reputation of the Bank, increasing public confidence in the Bank, strengthening the authority of the Employee and promoting effective cooperation with the European Central Bank and the European System of Central Banks. The Code has been developed following the Constitution of the Republic of Lithuania (hereinafter — Constitution), the Republic of Lithuania Law on Public Administration, the Republic of Lithuania Labour Code, the Republic of Lithuania Law on the Adjustment of Public and Private Interests in the Civil Service, the Republic of Lithuania Law on the Bank of Lithuania, the Ethics Framework of the European Central Bank (OJ 2015 C 204 p. 3), Guideline (EU) 2015/855 of the European Central Bank of 12 March 2015, laying down the principles of a Eurosystem Ethics Framework and repealing Guideline ECB/2002/6 on minimum standards for the European Central Bank and national central banks when conducting monetary policy operations, foreign exchange operations with the ECB’s foreign reserves and managing the ECB’s foreign reserve assets (ECB/2015/11) (OJ 2015 L 135, p. 23), Guideline (EU) 2015/856 of the European Central Bank of 12 March 2015, laying down the principles of an Ethics Framework for the Single Supervisory Mechanism (ECB/2015/12) (OJ 2015 L 135, p. 29) and other legislative acts. Terms used in the Code: 6.1. Close Associates — spouses, cohabitants, partners, when the partnership is registered in accordance with the procedure established by laws, as well as parents (adoptive parents), children (adoptees), brothers (step-brothers), sisters (step-sisters), grandparents, grandchildren and their spouses, cohabitants or partners, as well as other persons who may cause a conflict of interest. 6.2. personal interest — any benefit or potential benefit, of a financial or non-financial nature, for the Employee himself/herself, other Employees or Close Associates; 6.4. conflict of interest — any situation where Employees have personal interests which may influence or appear to influence the impartial and objective performance of their duties; 6.5. Heads — The Chair of the Board of the Bank, the Deputies, Members of the Board of the Bank, heads of structural units, branches and local subdivisions. CHAPTER II GENERAL PRINCIPLES OF CONDUCT The principle of respect to the individual and the State . Employees shall respect the individual, his/her rights and freedoms, the State, its bodies and institutions, abide by the Constitution, laws, other legislative acts, and court decisions. Employees shall refrain from any discrimination with respect to other individuals and all forms of harassment or abuse. The principle of justice. Employees shall treat all individuals on equal grounds, irrespective of their nationality, race, gender, sexual orientation, language, origin, social status, religious beliefs and political views, as well as act fairly in addressing the matters state in the applications and refrain from abusing the powers and authority granted to them. The principle of taking care of the public interests. Employees shall respect the public interests, use the assets and information entrusted to them only for the purposes of their service at the Bank, and refrain from seeking any personal benefits or benefits for Close Associates when performing their official duties. The principle of decency. The conduct of Employees shall be irreproachable; they shall be incorruptible, refuse accepting any gifts, money or services, exceptional privileges and discounts from individuals or organisations which might affect the independent performance of their official duties. The principle of impartiality. When adopting decisions, Employees shall act independently, objectively, honestly and without any preconceived notions. The principle of responsibility. Employees shall act cautiously, carefully and attentively. Employees shall be responsible and accountable for their decisions to the Heads. The principle of publicity. In accordance with the procedure established by legal acts, Employees shall provide required information to the public and other institutions as well as explain the reasons behind the motives for decisions; information shall be restricted only when there is a need to protect the public interests or when this is required by legal acts. Social conduct. Employees shall be encouraged to engage in social activities, charity events, support environmental protection projects by their actions, and participate in community activities and events promoting citizenship and volunteering. CHAPTER III CONDUCT OF HEADS AND EMPLOYEES SUBORDINATE TO THEM The Heads and Employees substituting them shall: 15.1. demonstrate by their behaviour and work an example complying with requirements of the Code; 15.2. communicate with subordinate Employees in a business-like and polite manner; 15.3. maintain conducive to work and friendly atmosphere at the Bank, try to preclude possible conflicts, eliminate root causes of disagreements; 15.4. express remarks related to work in tactful manner, without participation of Employees whom the remarks do not concern; 15.5. avoid expressing own sympathy or antipathy towards Employees and treat them according to their professional qualities; 15.6. encourage Employees, who help in identifying unfair behaviour, not to put up with violations of legal acts and participate in disclosing them; 15.7. never take revenge on the Employee or victimise him/her otherwise in any form whatsoever. Among themselves and with the Heads, the Employees shall: 16.1. present their opinions in a business-like and polite manner; 16.2. cooperate, share information with their colleagues, and contribute to the achievement of common goals. If the Employee is instructed to perform a task or assignment, which is incompatible with legal acts, the Employee shall have the right to refuse performing such a task or assignment. The Employee shall notify in writing of his/her decision the immediate superior and/or a higher-level manager as well as the compliance officer, specifying the reasons of the refusal to perform a task or assignment. Employees shall be prohibited from spreading any (potentially) incorrect or misleading information related to the activities of the Bank available to them. CHAPTER IV ACCEPTING GIFTS Employees shall be prohibited from, directly or indirectly, soliciting, receiving or accepting from financial market participants, service providers, suppliers of goods or other persons any gifts or exceptional conditions that do not ensure a level playing field, which are in any way connected to the work of the Employee and bring financial or non-financial gains to Employees or their Close Associates. When conducting inspections of the supervised financial market participants, only minor hospitality offered during a work-related meeting may be accepted. Employees shall assess particularly carefully offers and invites, both related to official duties and personal, and accept them only having made sure that this will not prevent the Employee from the proper performance of his/her duties at the Bank, harm the reputation of the Bank and the Employee, and result in a conflict of public and private interests. Before accepting an offer to participate at events hosted by private organisers, which are connected to his/her official duties, the Employee shall ascertain situations that could result in a conflict of interest and foresee potential ways of avoiding them. Employees shall refuse accepting offers to cover travel and living expenses and other expenses of a similar nature, should this have an impact on the independence of the Bank and the impartial and objective performance of Employees’ duties. Persons accompanying the Employee may attend the events related to the official duties of the Employee if such arrangements are specified in the invitation or such attendance is in line with the international protocol or long-standing traditions. CHAPTER V PROHIBITION TO USE INSIDE INFORMATION For personal gains or benefits for Close Associates or other persons, Employees shall be prohibited from using, consulting on or providing inside information or information related to the Bank’s financial asset investment, decisions and operations connected to interventions in the foreign exchange market or monetary policy, as well as non-public exact information closely related to securities auctions of the Government of the Republic of Lithuania and their participants, and non-public information related to the goals and objectives of the Eurosystem and to the supervision of the financial market. Employees shall be prohibited from engaging in betting on decisions adopted by, or with participation of, the Bank or on any events or phenomena directly linked to the position of Employees held with the Bank. CHAPTER VI WORK OUTSIDE THE BANK AND OTHER ACTIVITIES Employees shall not accept from third parties any remuneration for the activities related to their position in the Bank. Employees may work or engage in activities outside the Bank only in cases set forth by the Law on the Bank of Lithuania and if it does not interfere with the proper fulfilment of their duties at the Bank, does not create preconditions for a conflict of public and private interests, and/or discredit the reputation of the Bank or the Employee. (As amended by Resolution No 03-6 of the Board of the Bank of Lithuania of 5 January 2017) The Employee shall not be an elected (appointed) member of the management body of a private legal person, except in cases when he/she has been elected or appointed to the position of such member by the Bank or when the Employee has been elected following the provisions of the Republic of Lithuania Law on Associations of Owners of Multi-apartment Residential Buildings and Other Types of Buildings or of the Republic of Lithuania Law on Associations of Garden Plot Holders. (As amended by Resolution No 03-186 of the Board of the Bank of Lithuania of 18 October 2018, amendment comes into force on 1 January 2019) . “28. The Employee shall not be an elected (appointed) member of the collegial management body or supervisory body of a legal person, if that legal person is supervised by the Bank,if there may arise a conflict of interest, preconditions for the Employee to use his/her position in favour of private or legal person interests, if the Bank’s authority or reputation could be discredited, if the position could create obstacles for the Employee to execute functions set out in his/her job description,if the Employee in his/her position could make decisions related to the legal person and if other circumstances arise due to which the Employee cannot be an elected (appointed) member of the collegial management body or supervisory body of a legal person.” CHAPTER VII ADJUSTMENT OF PUBLIC AND PRIVATE INTERESTS Employees shall disclose their private interests and avoid any situations that could lead to a conflict of private and public interests. In case of a potential conflict of interest, Employees shall resign from any stages of drafting, deliberation, adoption of any issues and decisions whatsoever that cause a conflict of interests in accordance with the established procedure. After leaving service at the Bank, Employees shall observe restrictions laid down in the Law on the Adjustment of Public and Private Interests and the Description of the Implementation of the Code of Ethics of the Employees of the Bank of Lithuania. CHAPTER VIII OBLIGATION OF SECRECY Employees shall undertake to keep confidential the secrets related to the activities of the Bank and personal data, except in cases provided for by laws of the Republic of Lithuania and agreements of the Bank. Employees shall not personally use or provide possibilities for their Close Associates to use this information for personal interests. Employees shall keep information related to the activities of the Bank and information constituting the secrecy of personal data even after leaving service at the Bank. In providing information or otherwise processing personal data, Employees shall act in accordance with the requirements of legal acts and respect the data subjects’ right to privacy. CHAPTER IX PUBLIC COMMUNICATION Employees may provide in the mass media, on various websites, social media platforms (Facebook, Twitter, LinkedIn, Youtube, Instagram, blogs, etc.), etc. written or verbal information and comments about activities of the Bank only on coordination with the Communications Department of the Bank and the Head of their structural subdivision (Deputies and Members of the Board of the Bank — on consultation with the Chair of the Board of the Bank and having notified the Director of the Communications Department), except in cases when Employees are officially authorised to provide information, comments and the official position of the Bank on the matters related to activities of the Bank, or when they provide information which is periodically and publicly announced by the Bank. Employees may capture or collect information by taking photographs or videos, making video and/or sound recordings at the premises of the Bank or in its territory, live broadcast audio and/or visual information via technical means of communication, and publish such information in the mass media, on various websites, social media platforms (Facebook, Twitter, LinkedIn, Youtube, Instagram, blogs, etc.), etc. only on coordination with the Communications Department of the Bank, except in cases when Employees are officially authorised to do this, or when it is allowed pursuant to the procedure laid down in the legal acts of the Bank. Employees may express their personal opinions as private persons in the mass media, on various websites, social media platforms (Facebook, Twitter, LinkedIn, Youtube, Instagram, blogs, etc.), etc., only if they emphasise that such opinion does not reflect the official position of the Bank and that it is only their personal opinion, i.e. without giving the impression that they are representing the Bank. Employees shall not be able to use the symbols and logo of the Bank as well as the official email address for private (non-work related) purposes. When providing information and comments about the activities of the Bank or expressing personal opinions as private persons in the mass media, on various websites, social media platforms (Facebook, Twitter, LinkedIn, Youtube, Instagram, blogs, etc.), etc., Employees shall ensure that the secret related to the activities of the Bank will not be revealed. Bank documents, copies thereof, and official e-mails containing sensitive information shall not be made publicly available. When expressing their personal views as private persons, Employees shall not disclose information about other Employees or discuss them, as well as publish photographs, sound recordings and/or videos in any way connected to their personal lives without their permission. CHAPTER X FINAL PROVISIONS In accordance with the established procedure, the Employee who knows or can reasonably suspect that another Employee has potentially violated the provisions of the Code when performing his/her duties at the Bank, shall notify about it. The Bank shall guarantee that the confidentiality of this Employee will be ensured and that any wrong or discriminating treatment of this Employee shall not be tolerated. The compliance officer shall consult the Employees on the implementation of provisions of the Code. The Ethics Commission, in accordance with the Rules of Procedure of the Ethics Commission, shall examine potential violation of provisions of the Code that the Employees committed.