Whistleblower Policy


Any type of illegitimate and unethical activity that is / could breach laws and regulations applicable to the Company, including but not limited to any corruption, bribery, intentional harmful actions, breach of civil and administrative laws, intention breach of internal policies and procedures, harassment, bullying, etc.


UAB OPAY Solutions does not tolerate wrongdoing within the Company, with clients, and partners. Thus, we urge you to report any wrongdoing that has occurred.

UAB OPAY Solutions expects you to report in cases of:

non-compliance with the laws;

fraud, financial malpractice, or impropriety;

criminal activity, including bribery and corruption;

improper, unethical behavior of UAB OPAY Solutions representatives;

offences that have been, are being or are likely to be committed;

miscarriage of justice;

attempt to bribe or act of corruption activities;

act or omission that is discriminatory, grossly negligent or constitutes gross mismanagement;

personal grievances (e.g. bullying, harassment, discrimination);

The above list is a non-exhaustive list of examples. criminal activity, including bribery and corruption.


Please download the Notification Wrongdoing report form and, after completing it, send it to [email protected]; if the Wrongdoing relates to a Compliance Officer, send the form to [email protected]. You will be informed on the process of the investigation.


Any individual, including stakeholders, who reports a concern or notification about wrongdoing in UAB OPAY Solutions shall be guaranteed all the protections provided by the Law on Whistleblower Protection and Directive (EU) 2019/1937 of the EuropeanParliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.

All information disclosed by the reporting party and/or discovered during the investigation of wrongdoing will be kept confidential and will not be disclosed to any third parties before the investigation is concluded, except to the Senior Management of the company or competent authorities and officials, as necessary. Identifying information of the reporting party or individuals suspected of wrongdoing will only be provided to the entity or institution investigating the concern, with prior notification to he reporting party specifying the reasons for such disclosure.

UAB OPAY Solutions reserves the right to waive confidentiality obligations if the reporting party knowingly provides false information. The company ensures that all personal data collected during the investigation process will be managed in accordance with the Privacy Policy and other internal procedures governing the regulation of personal data of employees.


Stakeholders are encouraged to bring forth their concerns by reaching out to the Bank of Lithuania or other competent external authorities. Such reporting should adhere to the guidelines outlined in the Law on Whistleblowers Protection of the Republic of Lithuania, particularly in situations where:

The concern may significantly impact public interest;

The concern has the potential to cause substantial damage;

The concern involves Senior Management and/or Shareholders;

An internally submitted report was either disregarded or yielded unsatisfactory results;

There is a likelihood that confidentiality may be compromised when reporting through internal channels, or if there are concerns that the matter will not be adequately investigated due to attempts to conceal it, or if the reporting party feels pressured in any way.

Stakeholders are encouraged to follow these procedures when reporting concerns externally, ensuring compliance with legal requirements and the safeguarding of public interest and integrity within UAB OPAY Solutions.