Whistleblowing Policy
Terms used in the document
Term: description of the term
Defamation: 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, payswix’s members of staff.
Vexatious reporting: reporting with a sole purpose to cause annoyance, frustration or worry to payswix or payswix’s 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.
Introduction
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.
Scope
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 client’s,
public’s 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.
Principles
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.
Confidentiality of concerns raised
We expect that our external parties will feel able to voice whistleblowing concerns openly under this Policy. However, payswix will treat all disclosures in a confidential and sensitive manner. As part of this, the identity of any person making an allegation may be kept confidential (unless that person states that he or she wants to be identified) and so long as it does not hinder any parts of an investigation.
Anonymous disclosure
This Policy encourages external parties to put their name to any disclosure they make. Concerns expressed anonymously are less powerful and may be less easy to investigate; however, they will be considered and reviewed at payswix discretion.
In exercising this discretion, the factors taken into account will include:
• The seriousness of the issues raised;
• The credibility of the concern;
• The likelihood of confirming the allegation from attributable sources.
Untrue allegations or defamation
If an external party makes a genuine allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against them.
If the investigation reveals that the allegations were Malicious, Vexatious or pursue defamation of payswix reputation or any of payswix member of staff’s or client’s reputation, then disciplinary action may be taken against the external party.
Process of disclosure
If an external party believes that a matter or practice within the scope of this Policy
(article “Scope”) is or has been taking place, they should make the disclosure immediately. External party report their concerns confidentially via the „Whistleblowing form“ available on payswix website.
An investigation will then take place into the alleged matter or practice. When disclosing any concerns, the external party would not be expected to have absolute
proof of malpractice or illegal practices, but would need to show the sound reasons
for their concerns.
The designated payswix staff will decide whether sufficient information exists to allow the allegation(s) to be investigated and the „Internal Investigations“ process to be kicked-off.
Payswix will aim to keep the external party who raised the concern informed of the progress of any investigation and its likely timescale. However, sometimes the need for confidentiality may prevent payswix giving specific details of the investigation or any disciplinary action taken as a result.
Accessibility
Payswix is dedicated to guaranteeing the accessibility of our services to all our customers. Upon request, we will provide reasonable conditions and support, diligently working to remove barriers to inclusivity and equal access.
Training and Development
Payswix recognizes that its workforce is the bedrock of its operational excellence. To maintain the highest customer service standards, we are committed to continuously educating and empowering our staff through ongoing training efforts. These initiatives aim to equip our customer service team with the knowledge, skills, and tools necessary for exceptional performance and consistent alignment with customer and stakeholders expectations.
Monitoring and Review
Payswix consistently monitors and reviews its customer service operations to ensure compliance with the principles outlined in this CSS. Customer feedback is a vital part of this continuous process, driving systemic improvements and adaptive refinements to enhance service quality. Therefore, to keep up with clients’ feedback we send several surveys throughout a year – quarterly one to the customers that have been Payswix, UAB clients for 3 months and longer and a yearly survey is sent to all of our clients.
Final Provisions
Payswix, UAB, is firmly dedicated to providing exceptional customer service that aligns with our core values of customer focus, professionalism, and continuous improvement. This CSS serves as a guiding light for our team, reaffirming our unwavering commitment to delivering exceptional service excellence.