Question 1

Terms used in the document

Accepted Answer

Term: description of the termDefamation: the action of damaging the good reputation of a company or a person.External Party: any party with which payswix has a valid contract or any other form of established relationship  a client, service provider, outsourcing party, payment scheme partner, shareholders, etc.; this excludes company employees.Protected Disclosure: disclosure of information that members of staff reasonably believes tends to show malpractice. As a member of staff, you are protected from suffering any detriment as a result of your disclosure.Malicious reporting: reporting with a sole purpose to do harm to payswix, payswixs members of staff.Vexatious reporting: reporting with a sole purpose to cause annoyance, frustration or worry to payswix or payswixs members of staff.Whistleblowing: act of revealing information about activity within a company or a person that is deemed illegal, immoral, illicit, unsafe or fraudulent.

Question 2

Introduction

Accepted Answer

As a licensed Electronic Money Institution regulated by the Bank of Lithuania, Payswix, UAB (hereinafter  payswix) is committed to take the necessary actions to establish a proper whistleblowing process in the organization.The purpose of this Whistleblowing Policy (hereafter - Policy) is to establish the approach to Whistleblowing for external parties at Payswix.Payswix has developed this Policy to demonstrate its commitment to open and accountable management. The Policy is designed to allow external parties to disclose information that they believe shows malpractice, unethical conduct, or illegal practices in the workplace or in dealings with the clients, without being penalised in any way. This includes protecting external parties from any detriment or discrimination or litigation if they do report (i.e., blow the whistle on) improper or illegal conduct within the organisation. Protection does not extend to cases of defamation committed by external party on purpose, or situations where an external party wants to solely protect their individual or corporate interests.The aim of this Policy is to provide a mechanism for reporting, investigating and remedying any wrongdoing at payswix.Payswix is committed to maintaining an open culture with the highest standards of honesty and accountability, where external party can report any legitimate concerns in confidence in every area of its operation or cooperation with payswix. This Policy applies equally to all external parties.This document is prepared by using: the following documents:Law on Whistle-blowers Protection of the Republic of Lithuania; Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law. Directive about executing the Law on Whistle-blowers Protection of the Republic of Lithuania.

Question 3

Scope

Accepted Answer

This Policy is intended to allow concerns that relate to suspected wrongdoing or danger at work to be reported if they are reasonably believed to be in the clients, publics or payswix best interest. Such raised concerns may lead to changes in payswix policies and procedures.Examples of such concerns (which are not exhaustive) might include*: A criminal offence; The breach of a legal obligation or regulatory requirement; A miscarriage of justice; Obstruction of justice; A danger to the health and safety of any individual; Damage to the environment; Funding of illegal activities; Bribery or financial fraud; Unethical conduct (harassment); Unlawful purchase of product/s, service/s and/or goods; Deliberate attempt to conceal any of the above.*Please note that this list is non-exhaustive and you are free to report other concerns.

Question 4

Principles

Accepted Answer

This Policy offers protection to those external parties who disclose a whistleblowing concern. Payswix aim is that the wellbeing of any external party should not in any way be harmed as a result of that protected disclosure, whether the item reported proves to be true or not, provided the reporting was carried out in good faith.Subjecting any external party to a detriment because of a protected disclosure, including a member of staff who has been investigated as part of the disclosure, may be regarded as gross misconduct which will result in disciplinary action. A detriment includes dismissal, disciplinary action, threats, or other unfavourable treatment at a workplace.Payswix undertakes to protect any external party from any personal or corporate claims and from any detriment, victimisation, harassment or bullying as a result of their disclosure.This Policy is not designed to support an external party who wishes to question financial or business decisions that have been taken by payswix.In most cases, whistleblowing claims need to be made promptly and at the latest within the three-month period following the date of the act complained of. Limited exceptions may apply in particular circumstances only.

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