APPROVED
by the order No. V-117
of the Auditor General
of the Republic of Lithuania
23 June 2021
CODE OF ETHICS OF
THE NATIONAL AUDIT OFFICE EMPLOYEES
CHAPTER I
GENERAL PROVISIONS
1. The Code of Ethics of the National Audit Office employees (hereinafter referred to as the Code) establishes the values of ethics, behaviour representing these values (principles of ethics), and general requirements for the National Audit Office employees as well as the special requirements for public auditors and employees carrying out other assessments in the discharge of their duties at the National Audit Office and outside their work at the National Audit Office.
2. The Code is based on the Constitution of the Republic of Lithuania and the following Laws of the Republic of Lithuania: the Law on the National Audit Office, the Law on the Adjustment of Public and Private Interests, the Law on Corruption Prevention, ISSAI 130 - Code of Ethics, principles established by the Organisation for Economic Co-operation and Development for independent fiscal institutions, other legislation and considering the values of the National Audit Office.
3. The objectives of this Code are as follows:
3.1. To regulate the ethical values and general requirements to be observed by employees and the special requirements to be observed by public auditors and employees carrying out other assessments in the discharge of their duties laid down in legislation and outside their work at the National Audit Office;
3.2. To raise awareness among employees that their behaviour must be based not only on the requirements of the Code but also on the generally accepted standards of morality;
3.3. To ensure that employees serve the society and the state and discharge their duties for selfless purposes;
3.4. To help employees avoid conflicts with the staff of the entity;
3.5. To help regulate the relations between employees.
4. Definitions used in the Code:
4.1. Employee means the Auditor General, Deputy Auditors General, Head of Administration, public auditors, employees carrying out other assessments, also employees supporting the implementation of the tasks of the National Audit Office and/or performing internal administration, including functions of an economic and/or technical nature.
4.2. Discrediting means any act (or omission) that undermines the authority of the National Audit Office, destroys trust and confidence in it, and compromises it.
4.3. Public auditor means an employee of the National Audit Office who performs public audit and participates in the public audit process, and/or monitors public audit recommendations, and/or carries out assessments, who is sworn to the Republic of Lithuania and who has the rights and duties established by the Law on the National Audit Office.
Other terms used in the Code correspond to the ones used in the laws and regulations of the Republic of Lithuania.
CHAPTER II
GENERAL REQUIREMENTS OF ETHICS
5. The employee shall:
5.1. Follow the values of institutional ethics set out in the ISSAI 130 - Code of Ethics” and this Code as well as the requirements and the generally accepted standards of morality;
5.2. Discharge his/her duties and fulfil the requirements set out in the Law on the National Audit Office, the Labour Code of the Republic of Lithuania, and other legislation that regulates his/her activities, beyond reproach and responsibly;
5.3. Behave selflessly and in such a way as to be useful to society and the state;
5.4. Avoid conflict of public and private interests, behave in such a way as to avoid the appearance of such a conflict, and observe the provisions of the Law on the Adjustment of Public and Private Interests and the provisions of legislation related to the implementation of the said Law;
5.5. Inform immediately according to his/her direct supervision the head of the structural unit, Head of Administration, Deputy Auditor General, or the Auditor General about the emergence of a conflict of public and private interests and refrain from participation in the further procedure for the preparation, consideration, and adoption of a decision;
5.6. Follow prior written recommendations on which actions and procedures for the preparation, consideration, or adoption of decisions giving rise to a conflict of interest, whatever they are designated (deliberation, informal consultation, presentation of an issue, etc.), the employee must refrain from, and the measures he/she has to take to ensure that his/her activities are carried out in accordance with the requirements of the Law on the Adjustment of Public and Private Interests;
5.7. Immediately inform in writing the persons referred to in the recommendations as soon as the circumstances giving rise to a conflict of interest no longer exist;
5.8. Refrain from influencing other employees regarding their work, unless otherwise provided by laws and regulations;
5.9. Refrain from violating human rights and dignity, respect the persons and institutions he/she communicates with, and treat all persons equally, regardless of their nationality, social background and status, sex, racial or ethnic origin, language, age, religious beliefs, political opinions, sexual or other attitudes;
5.10. In the discharge of his/her duties and outside working hours, refrain from discrediting the authority of the institution by his/her conduct, set an example for others, follow the recommendations for a dress code established at the institution;
5.11. Immediately inform the head of the structural unit and the person responsible for controlling the declaration of private interests about the cases of detention, court sentences against him/her, and the opening of bankruptcy proceedings;
5.12. Refrain from abusing alcohol, from using psychotropic or narcotic substances for other than medical purposes;
5.13. Refrain from using property of the state, state bodies, and institutions in breach of the law;
5.14. Refrain from abusing his/her duties or using documents that verify his/her position and powers, and requisites of the National Audit Office in order to influence persons outside his/her control to make a decision to his/her advantage;
5.15. Refrain from public comments (including mass media, websites, and social networks) on the institution, its activities, other employees of the National Audit Office, his/her work that could form a negative opinion of the public or its members about the institution, as well as activities of other state institutions and bodies without prior the order from the management of the institution.
CHAPTER III
GENERAL ETHICAL VALUES
Integrity
6. Integrity is considered a valuable measure of a person's behaviour, the ability to consciously evaluate and regulate his/her behaviour in accordance with moral standards, to understand the moral value of his/her actions and the responsibility for them.
In observing this value, the employee shall:
6.1. Show a good example and behave impeccably, reliably and benevolently;
6.2. Follow the values set by the institution in the implementation of the institutions’ strategy in the discharge of his/her duties;
6.3. Discharge duties and use powers, information, and resources solely in the public interest, not use their duties to obtain privileges and benefits for themselves or others;
6.4. Know who to consult with on the issues of employee ethics;
6.5. Attend training, meetings, and events for the development of ethics;
6.6. Be aware of the circumstances that may affect his/her vulnerability to his/her integrity while working in the institution and avoid such circumstances.
These circumstances may be related to:
6.6.1. Personal, financial, or other interests or relationships that may conflict with the interests of the institution;
6.6.2. Abuse of power for personal benefit;
6.6.3. Engagement in political activities, participation in lobbying activities;
6.6.4. The possibility to access classified information;
6.6.5. The possibility to access and use the resources of the institution;
6.6.6. Other factors.
Independence and impartiality
7. Independence is a situation in which an employee can discharge activities without any influence that could affect and compromise professional judgment, can act principally, and maintain objectivity and professional scepticism.
8. Objectivity is considered as the approach by which the employee is capable of acting impartially and presenting or evaluating things based on facts rather than feelings and interests, without trusting the decision to others, and the employee of the Budget Monitoring Department - based on reasonable assumptions.
9. An employee must avoid threats to independence and objectivity related to political views, leadership, self-control, financial or other personal interests, relationships with others, and their influence.
In observing this value, the employee shall:
9.1. Remain politically neutral and refrain from public expression of their political beliefs and from agitation, to identify situations when personal political views may undermine his/her independence or objectivity, or when his/her political views and actions may endanger the reputation of the institution and trust in its activities;
9.2. Avoid circumstances when private interests could influence decision making or make such an impression on the public;
9.3. Refuse gifts, services, or benefits if that is related to his/her status or position;
9.4. Inform according to his/her direct supervision the head of the structural unit, the Head of Administration, the Deputy Auditor General, or the Auditor General about all previously or currently existing relations and situations that may endanger its independence or impartiality.
Competence
10. Competence is considered as a set of knowledge, skills, and attitudes in a given field, proven ability to perform tasks and, actions following agreed requirements.
In observing this value, the employee shall:
10.1. Perform duties in accordance with the provisions of legal acts, recommendations, standards, contracts or agreements, established or agreed terms, and good practices of public audit;
10.2. Understand the functions and tasks performed;
10.3. Act thoroughly, carefully, in accordance with the requirements of the task and given authorization;
10.4. Maintain, develop, and expand his/her knowledge and skills to keep up with the development of his/her professional environment and optimally discharge his/her duties, gain new knowledge and skills;
10.5. Be able to work in various situations depending on work or task requirements;
10.6. Inform the head of the structural unit if the experience is not appropriate or sufficient to perform a specific task.
Professionalism
11. Professionalism is considered to be such an action that would allow a third party, which has the knowledge and relevant information, to conclude that the work meets the applicable legislation and standards.
In observing this value, the employee shall:
11.1. Comply with the provisions of laws and regulations, agreements, as well as acceptable behaviour that conform with the values of the institution, which are obligatory in the working environment and outside it;
11.2. Understand and consider the impact of his/her actions on the trust of the institution and take into account the expectations of other persons (colleagues, family members, friends, the entity, media, etc.) regarding his/her behaviour in the work environment and private life;
11.3. Refrain from abusing his/her duties, be careful and attentive in his/her duties and when communicating with other persons that his/her actions or expression of opinion do not compromise the institution and do not undermine its authority (including the usage of social media);
11.4. Cooperate within the institution, share knowledge and information;
11.5. Avoid actions that, although legally permitted, do not comply with a standard of professional ethical behaviour.
Confidentiality and transparency
12. Confidentiality is considered to be the obligation to ensure the use of information, obtained in the course of performing duties, only for the purposes of work.
Transparency is understood as an obligation to obtain disclosure of all procedures, criteria, and models based on which the public audits and assessments of the National Audit Office are conducted.
13. In observing this value, the employee shall:
13.1. Be aware of the responsibilities and legal regulation of the institution regarding confidentiality and transparency;
13.2. Refrain from disclosing any information obtained in the discharge of his/her duties without proper and specific permission, except the cases when he/she has a statutory or professional right or obligation to do so, preserve the secrets of state and service;
13.3. Refrain from using and deny access to any information that was obtained during his/her duties to meet the needs of his/her own, close persons or third parties;
13.4. Maintain professional confidentiality during and after the employment;
13.5. Ensure the confidentiality of information when discussing work with other employees and in private life: in the family, in social or other environments, including social media, assess the risk of accidental disclosure;
13.6. Ensure the protection of electronic data devices (laptops, portable data carriers) and mobile phones, and the confidentiality of passwords.
CHAPTER IV
SPECIAL REQUIREMENTS FOR PUBLIC AUDITORS AND EMPLOYEES CARRYING OUT OTHER ASSESSMENTS
14. Public auditor shall follow the oath he/she is under;
15. Public auditor and an employee carrying out other assessments shall:
15.1. Demonstrate impeccable conduct with the staff of the entities, refrain from giving rise to distrust, avoid any relations with the staff of the entity that may lead to conflict of interest or create a visibility of conflict of interest, inform in writing the head of the structural unit or the Deputy Auditor General to whom the structural unit is directly subordinate of job searches within the entity and of any offers of transfer to the entity;
15.2. Be equally attentive and demanding to all persons in performing his/her duties; listen to the arguments of all parties in conflict situations and seek an objective judgment; do not have personal prejudice, ensure that decisions taken are lawful, and have no selfish motives;
15.3. Not participate in the decision making process of the management of the entity;
15.4. Not audit and assess his/her own work;
15.5. Use the information about the entity, which was collected during the public audit or other assessment, only for preparing the public audit report and public auditor’s report and for performing tasks;
15.6. Get to the heart of the matter of audits and assessments, avoid haste and superficiality, also avoid delay in the process, and comply with agreed terms;
15.7. Base the conclusions and recommendations only on appropriate and reliable evidence collected in accordance with the provisions of relevant legal acts, refrain from intentionally distorting information in the documentation;
15.8. Not publish data on public audit or assessment and not publicly evaluate them until the public audit or assessment report has been signed and made public.
15.9. When making public statements on issues not related to the activities of the National Audit Office and when expressing personal opinions, not give the impression that they are representing the National Audit Office and must clearly state that these are their opinions as private persons. Employees must not use the National Audit Office's symbols and logo for personal (non-professional) purposes.
16. Public auditor and the employee carrying out other assessments shall be prohibited from carrying out a public audit and/or participating in the public audit process and/or monitoring the recommendations of a public audit and/or carrying out an assessment if they:
16.1. Have a blood or marriage relationship with the manager, head of the administration, chief financial officer (accountant), project implementor, or members of the council or board of the entity;
16.2. Used to be an employee of the entity and was engaged in or responsible for activity during the period covered by the scope of the audit and less than one year has passed since the end of the employment relationship;
16.3. Is a shareholder of the entity, or if less than one year has passed since the transfer of shares;
16.4. Has received a loan from the entity or has other financial obligations to the entity;
16.5. Is affected by other conditions that may influence his/her independence.
17. Upon the occurrence of the circumstances referred to in the paragraph 16, the public auditor or an employee carrying out other assessments at the National Audit Office shall refuse to carry out an assignment to perform a public audit and (or) participate in a public audit process, and (or) monitor public audit recommendations and (or) carry out other assessments notifying in writing the head of the structural unit or the Deputy Auditor General to whom the structural unit is directly subordinate.
CHAPTER V
RELATIONS BETWEEN EMPLOYEES
18. Relations between employees shall be based on politeness, honesty, respect, tolerance, trust and active assistance.
19. An employee shall not discriminate, harass, bully, intimidate, or order discrimination against other employees on the grounds of sex, race, nationality, citizenship, language, origin, social status, religion, beliefs or opinions, age, sexual orientation, disability, ethnicity, religion or any other grounds. Employees must not tolerate or encourage discrimination and must be intolerant of perceived incidents of discrimination, harassment, or sexual harassment.
20. Employees shall show solidarity with their colleagues, protect them from undue criticism, and warn them about bad influence.
21. Employees shall refrain from analysing actions performed by their colleagues or assessing the competence of other colleagues in public.
CHAPTER VI
REQUIREMENTS FOR SENIOR STAFF OF THE NATIONAL AUDIT OFFICE
22. A senior staff member of the National Audit Office is obliged to:
22.1. ensure a collaborative management style that encourages employee initiative and autonomy and allows subordinate employees to participate in problem solving by working together;
22.2. endeavour to create a working and friendly environment within the management team, to prevent conflicts and to address the causes of disagreements;
22.3. communicate with and instruct subordinate employees in a courteous manner;
22.4. comment on the mistakes and shortcomings of subordinate employees in a correct manner, without the presence of other employees or persons;
22.5. endeavour to distribute the work of the management team evenly to make effective use of the capabilities and qualifications of each subordinate;
22.6. not to express his/her likes and dislikes towards subordinate employees and other staff members of the institution, and to evaluate subordinate employees on the basis of their qualities;
22.7. encourage and listen to the views of subordinate employees;
22.8. give due recognition to the service achievements of subordinate employees;
22.9. encourage the continuous development of subordinate employees;
22.9. encourage the continuous development of subordinate employees;
22.10. endeavour to ensure that subordinate employees have an appropriate working environment.
CHAPTER VII
OBLIGATION AFTER LEAVING THE NATIONAL AUDIT OFFICE
23. Employees, except those performing functions of an economic and/or technical nature, shall be required to avoid, for a period of one year after leaving office, any conflict between their public and private interests which might arise as a result of their new activities. If they intend to undertake an activity that could give rise to a conflict of public and private interests, they shall inform the National Audit Office in writing and seek its opinion in the form of a recommendation before committing themselves to it.
24. Requests for such an opinion shall be dealt with in accordance with the procedure laid down in the Regulations of the Ethics Commission of the National Audit Office.
CHAPTER VIII
FINAL PROVISIONS
25. Employees shall not execute assignments if the assignment forces them to break the law, other legislation, International Standards on Auditing, International Standards of Supreme Audit Institutions, or this Code. The employee shall inform in writing in accordance with his/her direct subordination the head of the structural unit and also notify the Head of Administration, the Deputy Auditor General, or the Auditor General.
26. The employee shall inform the Auditor General and Official Ethics Commission of the National Audit Office about the fact known to him/her that another employee has breached the provisions of the Code while discharging his/her duties in the institution when he/she has reasonable grounds for suspicion of a possible breach of the provisions of the Code. The employee who has reported a breach of the Code is guaranteed that unfair or discriminatory behaviour towards him/her will not be tolerated and the confidentiality of his/her identity will be ensured upon request.
27. All the employees shall acquaint themselves with the Code by means of the Document Management System and commit to follow it.
28. Breaches of ethics shall be investigated in the procedure laid down by the Auditor General.
29. In cases when the employee's conduct is not governed by this Code, he/she shall comply with the ethical standards set out in other legislation as well as generally accepted standards of morality.
_______________________________