The whistleblowing rules

SAS Manpower Lit branch Manpower Lit internal whistleblowing rules


1. Purpose

The purpose of the rules is:

Provide a whistleblowing system in the SAS Manpower Lit branch Manpower Lit (hereinafter – Manpower) that meets the requirements of regulatory acts;

Determine the procedure by which Manpower provides the opportunity for employees, partners and other persons who perform any work for Manpower to report possible violations;

Determine a set of measures that ensure the protection of employees who have reported possible violations;

Ensure proper evaluation of reports and appropriate action in case of violation.



2. Whistleblower

A whistleblower is a natural person who provides information about an alleged violation that may harm the interests of the public, provided that the individual considers it to be true, and if information about such a violation is acquired as part of one’s work duties or as part of establishing a legal relationship related to work duties.

Deliberately providing false information is not whistleblowing, and the whistleblower may be held liable for it in accordance with regulatory acts


3. The purpose of whistleblowing

The purpose of whistleblowing is to prevent a threat to the public and to inform about a threat to the public interest, that is, an action by Manpower that may endanger a part of the public or some essential interests of the public.

A report on a violation of personal interests (an action where the main motive is a personal complaint, personal disagreements or obtaining some personal, including material benefit) is not whistleblowing.



4. Reportable offences

Internal whistleblowing can be raised for criminal offences, administrative violations or other violations of legal norms or violations of binding ethical or professional norms, but especially for such violations – inaction, negligence or abuse of the official position by officials, corruption, fraud, embezzlement of financial resources or property of a public person, tax evasion, threats to public health, threats to construction safety, threats to environmental safety, threats to work safety, threats to public order, violations of human rights, public procurement violations, violations of competition law.

The above list of violations is not exhaustive.



5. Whistleblowing channel

The Whistleblower report (hereinafter referred to as the Report) can be submitted electronically by sending the report to the e-mail address: [email protected].


6. Content of the Report

The whistleblower submits the Report in free form or uses the Whistleblower report form (Appendix No. 1).

The Report states:

name, surname, contact information of the whistleblower;

detailed information related to the violation (or alleged violation), separately indicating the facts and the persons involved, as well as attaching evidence, if any;

details about how information on the violation was obtained (for example, while performing work duties);

information on whether the violation was previously reported;

that it is a Whistleblower report.


7. Responsibility

The responsible person at Manpower for the processing and review of the Report is a Personnel Specialist – Team Leader (hereinafter – Responsible person).

Responsible person:

accepts and registers the Whistleblower report;

conducts the initial evaluation of the Report and makes a decision on the further progress of the Report;

properly stores and destroys the Report and related documents;

if required, provides consultation related to whistleblowing.


8. Personal data processing, pseudonymisation of reports, confidentiality

Manpower processes the personal data of the whistleblower and the alleged infringer for the purpose of conducting an investigation of the alleged breach, ensuring adequate protection of the whistleblower and ensuring communication with the whistleblower.

Personal data of the whistleblower and alleged infringer is only processed for Manpower to comply with Manpower’s legal obligation under the Whistleblowing Law to establish an internal whistleblowing system.

The Responsible person of Manpower, upon receiving the Report, takes the necessary measures for the protection of the whistleblower in accordance with Article 11, Part 2 of the Whistleblowing Law. In a Report containing the personal data of the person submitting the report, all relevant personal data are pseudonymised by replacing the personal data with another identifier. Reports are recorded separately and stored securely in accordance with the Personal Data Processing Regulations of Manpower.

Manpower ensures that the identity of the whistleblower and the persons mentioned in the Report (person involved in the alleged violation) is not disclosed. The Responsible persons are prohibited from disclosing to third parties the personal data in their possession related to the Report without a valid reason or separate consent of the whistleblower. The mentioned information can only be provided to a person or an institution that needs it for the investigation of the whistleblower report or a violation case initiated on its basis, or for the protection of the whistleblower or their relatives.

The person about whom a Whistleblower report has been submitted may be informed of such Report in order to give an opportunity to provide relevant explanations. However, this person does not have the right to receive information that may indicate the whistleblower’s identity.

Manpower ensures that the identity of the whistleblower is not disclosed to persons not involved in the investigation of the alleged violation.


9. Deadline for the consideration of reports

Regarding the whistleblowing process, the Responsible person shall, no later than within 7 (seven) days from the day of receiving the Report, evaluate the prima facie compliance of the whistleblower’s submission with the requirements of the Whistleblowing Law, make a decision on the recognition or non-recognition of the submission, the Whistleblower report and the further progress of the Report, and inform the submitter.

If, upon evaluating the application, the Responsible person finds that there are deficiencies in it that could have arisen due to carelessness, they shall refer to Article 9.1 of this procedure within the period mentioned in the paragraph, and contact the submitter of the Report, asking to provide additional information or to clarify the Report.
If the Responsible person makes a decision to recognise the submission as a Whistleblower report, they inform Manpower’s management about the received Report and submit the Report to the relevant commission for review on its merits.


10. Review of whistleblowing reports

The Report received by Manpower is reviewed by the Whistleblowing Report Review Commission (hereinafter referred to as the Working Group), established by order of the Manpower management and consisting of 3 (three) members.

The Working Group ensures equal and fair consideration of the merits of all whistleblowing reports submitted.

In order to facilitate a proper and comprehensive investigation of the whistleblowing report, the Working Group has the right to familiarise itself with all documents and/or materials relating to the circumstances indicated in the Report.

The whistleblower is informed about the progress of the review of the Whistleblower report no later than within 2 (two) months from the day when the person’s submission is recognised as a Whistleblower report. The term of consideration of the Report depends on the circumstances of the alleged violation indicated in the Report.


11. Result of consideration of reports

If, during the consideration of the Report, a violation by a person is detected or a possible violation is objectively proven, the Working Group informs the Manpower management accordingly.

Manpower takes appropriate measures to prevent the consequences of a violation or to prevent the commission of a violation and depending on the circumstances of the violation (possible violation), Manpower, without exceeding the limits of its competence, takes corrective actions, as well as other measures, including control improvement.

If, during the consideration of the Report, the suspicion of a violation arises, the consideration of which is not within the competence of the Working Group, Manpower forwards the Report for further consideration to the relevant state or local government institution, law enforcement agency or whistleblower contact point within 7 (seven) days and informs the submitter about such in writing.


12. Prohibition of adverse consequences

The whistleblower and their relatives are prohibited from being disciplinarily or otherwise punished, dismissed from work or position, demoted, transferred to another job or position, or otherwise directly or indirectly causing adverse consequences to them because the whistleblower has submitted a Whistleblower report.


13. Duration of personal data processing (Storage of the Report and related documents)

Statistical information and data on reports will be kept for at least 3 (three) years after the completion of the investigation, unless otherwise stipulated by regulatory acts.

A Report that is not recognised as a Whistleblower report, as well as the information related to it, is immediately deleted, or destroyed.

A report recognised as a Whistleblower report, as well as 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 Report.


14. Consultation options

14.1. A potential whistleblower may seek advice before preparing a potential report:

a) personally, to the person responsible for whistleblowing;

b) ask the questions they are interested in by sending an e-mail to [email protected]


15. Closing provisions

Manpower presents the Terms by:

publishing the Terms on the Manpower website:;

Manpower employees are informed of these Terms when starting employment legal relations.

These Terms are valid to the extent that they are not contrary to the laws in force in the Republic of Latvia and come into force after their approval.


Appendix No. 1 - The Whistleblower report form

The report form