Whistlblowing Policy


1. Definitions used

Responsible persons

The Head of the Human Resources Department of the Company and the Lawyer, who perform the following duties: receive and register the application of a person, assess the compliance of the application with the whistleblower's message and make the relevant decision, pseudonymize the whistleblower's personal data, review the whistleblower's message, ensure communication with the whistleblower and other institutions, perform the duties of a contact person.

Performance of work duties

Performing certain work, including volunteering, professional or position duties or providing services in the Company.


A natural person who, on the basis of an employment contract, performs certain work under the direction of the Company (employer) for the agreed remuneration.

Working group

The application received at the Company shall be reviewed by the whistleblowing message review committee established by the order of the Board and composed of 3 (three) or more members of the committee.

Cooperation partner

All legal and natural persons, including public authorities and officials, (i) who use the Company's opportunities – to purchase goods or receive services, or (ii) from whom the Company buys goods and/or services in order to use them for self-consumption or to sell them to Customers.


Whistleblowing policy.


A criminal offence, administrative offence or other violation of legal norms (activity or inactivity), including conduct contrary to the purpose of the law, as well as violation of binding ethical or professional norms.


A natural person who supplies information about an alleged violation, which may harm the public interests, if person believes that this information is true and it has been obtained during performance of his or her work duties or while establishing a legal relationship, which is related to the performance of the work duties, or during practice, and who could be adversely affected due to the supply of this information.

Contact point for whistleblowers

The contact point for whistleblowers is the State Chancellery, address: 36 Brīvības bulvāris, Rīga, LV-1050, more information here: https://www.trauksmescelejs.lv

Fair Play channel

An independent and secure whistleblowing channel that provides an alternative and anonymous way to report suspected violations or misconduct. The reporting channel is located outside the Company's IT environment – Whistle B., available from here: https://www.domenikss.lv/par-mums/atbildiga-un-tiesiska-darbiba


Limited liability company “DOMENIKSS”, registration number 40003363354, legal address: Varšavas iela 4, Rīga, LV-1003.


Whistleblowing message

2. Purpose of the regulations

2.1.The purpose of the regulations is to promote the whistleblowing in the public interest about the Violations and to ensure a whistleblowing system compliant with the requirements of the Company's regulatory enactments, as well as adequate protection of the whistleblowers.

2.2. To stipulate the procedure by which the Company provides an opportunity for the Employees, Cooperation Partners and other persons who perform work for the Company or in the context of the management of the Company's activities to report violations.

2.3. To ensure proper evaluation of the Messages and appropriate action in the event of a violation.

3. Violations for which an alarm is to be raised

3.1. The alarm shall be raised for criminal offenses, administrative offenses or other violations of legal norms or violations of binding ethical or professional norms.

3.2. The whistleblower shall be entitled to raise the alarm in particular for the following violations:

3.2.1. corruption;

3.2.2. conflict of interests;

3.2.3. fraud;

3.2.4. tax evasion;

3.2.5. unfair competition and antitrust infringement;

3.2.6. environmental safety risks;

3.2.7. occupational safety risks;

3.2.8. discrimination or unequal opportunities;

3.2.9. bullying or harassment;

3.2.10. failure to comply with laws and regulations;

3.2.11. other unethical behaviour;

3.2.12. other matters forming part of national legislation on whistleblowing.

3.3. Deliberately misrepresenting and reporting only violation of personal interests is not considered a whistleblowing.

4. Whistleblowing channel

4.1. The Message shall be submitted electronically to the Company's whistleblowing channel:

4.1.1. email address:  ; or

4.1.2. via the Fair Play whistleblowing channel.

4.2. The Company also provides, that the Whistleblower as an Employee may submit the Message in person to his/her direct manager or the Company's Board.

5. Message contents

5.1. The Message shall be submitted by the Whistleblower in the form of a free submission or in accordance with the model set out in the Annex.

5.2. The reported event must be described clearly and accurately, so that appropriate additional measures can be taken. If necessary, the Message may include attachments. The content of the Message shall include:

5.2.1. the name, surname and contact details of the submitter;

5.2.2. details of the violation (or suspected violation), with a breakdown of the facts and parties involved, and, if available, evidence attached;

5.2.3. information on how the info of violation was received (e.g. during performance of work duties);

5.2.4. information on whether the violation was previously reported;

5.2.5. that this is the Whistleblower's Message.

5.3. If the Message is sent by e-mail, the Message Subject should include: “Whistleblower's Message”.

5.4. If the Message is sent via the Fair Play whistleblowing channel. When opening the whistleblowing channel Fair Play, the Whistleblower must answer the following questions and provide detailed information about the case, in accordance with Clause 5.2 of the Rules:

5.4.1. What is the subject of the message?

5.4.2. When did it happen?

5.4.3. Where did it happen?

5.5. Any type of message may be submitted within 6 (six) months from the date on which there is reason to believe that the informant, including the Whistleblower, could have learned the facts on which the message is based.

5.6. Messages sent by e-mail or on the Fair Play whistleblowing channel are handled in an equal and confidential manner. Messages may only be processed by the Responsible persons.

5.7. The Whistleblower message may not be submitted anonymously. Submitted messages that do not identify the submitter are not considered Whistleblower's Messages.

6. Responsibility

6.1. Responsible persons shall be replaced in their absence by an appropriate employee appointed by the Board.

6.2. Responsible persons:

6.2.1. accept and register the Whistleblower's Message;

6.2.2. carry out the initial evaluation of the Message and decide on the further progress of the Message;

6.2.3. properly keep and destroy the Message and related documents;

6.2.4. if necessary, provide advice related to Whistleblowing.

7. Processing of personal data, pseudonymisation of Messages, confidentiality

7.1. The Company processes the personal data of the Whistleblower and the alleged violator for the purpose of investigating the alleged violation, ensuring adequate protection of the Whistleblower and ensuring communication with the Whistleblower.

7.2. The personal data of the whistleblower and the alleged violator shall be processed only for the purpose of Company's compliance with the legal obligation imposed on the Company by the Whistleblowing Act regarding the creation of the Whistleblowing system.

7.3. Upon receipt of the Message, the Company's Responsible Persons shall take the necessary measures to protect the Whistleblower in accordance with the Whistleblowing Act. In a message containing the personal data of the reporting person, all relevant personal data shall be pseudonymised by replacing the personal data with another identifier. Messages are registered separately and their secure storage is ensured, by observing the Company's Personal data processing regulations.

7.4. The Company shall ensure that the identity of the Whistleblower and the persons mentioned in the Message (the persons involved in the alleged violation) is not disclosed. Responsible persons are prohibited from disclosing to third parties personal data related to the Message in their possession without a valid reason or separate consent of the Whistleblower. Such information may only be provided to a person or body who needs it for the purposes of the investigation of the Whistleblower's Message or of violation proceedings initiated on the basis thereof, or for the protection of the Whistleblower or his relatives.

7.5. A person about who a whistleblowing Message has been issued may be informed of such a Message in order to give the opportunity to provide respective explanations. However, this person does not have the right to receive information that may indicate the identity of the Whistleblower.

7.6. The Company shall ensure that no information is disseminated that discloses the identity of the person reported by the Whistleblower to persons not involved in the investigation of the alleged violation. Only those Employees or persons who are strictly necessary for the conduct of the investigation will be informed of the investigation and the respective message. Employees or persons, to who the information provided by the whistleblower relates, may not participate in the monitoring of the message, thereby ensuring that the reporting of conduct contrary to the principles of responsible and legal (sustainable) conduct does not have a negative effect on the person that has reported such a conduct and has provided his or her contact details.

8. Message examination deadline

8.1. The Responsible persons for the whistleblowing process, no later than within 7 (seven) calendar days from the date of receipt of the message, shall assess the prior compliance of the Whistleblower's application with the requirements of the Whistleblowing Act, adopt a decision on the recognition or non-recognition of the application as the Whistleblower's Message and the further progress of the Message, and shall inform the submitter thereof.

8.2. If the Responsible persons, during the assessment of the submission, find out, that it contains deficiencies, that may have occurred due to negligence, they, within the period referred to in section 8.1 of these Rules, shall contact the submitter and request additional information or clarification of the submission. If the Whistleblower receives additional questions, it is the Whistleblower's responsibility to respond promptly and to follow the instructions.

8.3. If the Responsible persons take a decision on the recognition of the submission as the Whistleblower's Message, they shall inform the Board and the personal director within the Veho Group about the Message received and, after the establishment of the Working Group, they shall submit the Message to the respective committee for examination on the merits.

8.4. If the investigation of the suspicion leads to a criminal investigation by the authorities, the information relating to the case shall also be provided to those involved in the investigation or who are legally entitled to receive the information in accordance with the authority's right to receive the information. This shall also apply to the contact details of the whistleblower, if he has provided them. The Whistleblower will be informed in case, if criminal proceedings are initiated.

8.5. If during the investigation of a message it is determined that the message has been submitted unintentionally or with the intent to deliberately harm the subject of the message, and the Whistleblower is identified, the Company may take measures in accordance with generally accepted procedures in the field of human resources management.

8.6. Deliberately providing false information is not whistleblowing and may be subject to liability as stated by the law.

9. CommitTee for the examination of Whistleblowing messages

9.1. The Working group shall ensure the fair and equitable handling of all whistleblowing Messages submitted.

9.2. In order to facilitate a proper and comprehensive investigation of the whistleblowing Message, the Working group shall have the right to inspect all documents and/or materials related to or relevant to the circumstances specified in the Message.

9.3. No later than within 2 (two) months from the date of acknowledgement of the person's submission as the whistleblower's Message, the Whistleblower shall be informed about the progress of the whistleblower's Message review. The time limit for the examination of the Message shall depend on the circumstances of the alleged violation specified in the message.

10. Result of message examination

10.1. If during the examination of the Message a violation of any person is found or an alleged violation is objectively proven, the Working group shall inform the Board of the Company accordingly.

10.2. The Company shall take appropriate measures to prevent the consequences of the violation or to prevent the violation, as well as, depending on the circumstances of the violation (possible violation), the Company, within the limits of its competence, shall take corrective actions as well as other measures, including improvement of control.

10.3. If during the examination of the Message there is a suspicion of a violation, the examination of which is not within the competence of the Company, the Company, within 10 (ten) days, shall forward the Message for further examination to the relevant state or local government institution, law enforcement authority or the Whistleblowers Contact Point, and shall inform the submitter thereof in writing.

11. Prohibition of creating adverse effects

11.1. It is forbidden to cause adverse consequences to the Whistleblower, his relative and related person due to the whistleblower's Message and (if applicable): punish disciplinary or in other way; dismiss, including by not extending the employment contract or not appointing for an indefinite period, if there was a reason to believe that this would be done; transfer to another job or position; deny promotion, vocational training or further training; change the job or position duties, working hours and place of work or pay; provide negative assessment of work, position duties; offend honour, dignity and reputation; revoke licenses and permits; unilaterally withdraw from the contract for the supply of goods, purchase or service or terminate it; request a doctor's opinion; otherwise, directly or indirectly, cause adverse consequences, including by violating the principle of equal treatment.

11.2. The person responsible for causing adverse consequences to the Whistleblower, his relative or related person shall be subject to administrative liability.

12. Duration of the processing of personal data (storage of the Message and related documents)

12.1. Statistical information and data on Reports will be kept for at least 5 (five) years after completion of the investigation, unless otherwise required by law.

12.2. A message, that is not acknowledged as a Whistleblower's Message, as well as related information, is immediately deleted or destroyed.

12.3. The Message, that is recognised as the Whistleblower's Message, as well as the related information, shall be deleted or destroyed within 3 (three) years after the completion of the investigation, unless disciplinary proceedings or legal proceedings are initiated against the person accused in the message.

13. Other provisions

13.1. The Company introduces the Rules by publishing the Rules on the Company's website: https://www.domenikss.lv/. The Company's Employees are informed about these Regulations when entering into employment legal relationship.

13.2. These Regulations shall be effective to the extent that they do not contradict with the legislation in force in the Republic of Latvia and shall enter into force upon their approval and shall remain in force until new regulations are issued or amended. The Company is entitled to revise these Terms at any time.