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Ethics

Code of Ethics of employees of Riigi Kinnisvara AS

The Code of Ethics provides for important ethical principles imposed on the employees of Riigi Kinnisvara Aktsiaselts (hereinafter the Employer) and highlights activities that are considered permissible and impermissible. The Code of Ethics is based on the values of Riigi Kinnisvara AS, which include competence, diligence and reliability, and also on the good practices, traditions and generally accepted moral standards applicable in our cultural area.

  • It is important to the Employer that employees are treated equally and that the relationship between the Employer and the employees is based on trust and respect. All employees are treated with equal respect regardless of their position. Interactions between co-workers and partners can be described as helpful, polite and friendly.
  • Employees are law-abiding, dignified and acknowledge that shortcomings in their professional activities or undignified conduct also have an effect on the Employer's reputation and reliability. Employees refrain from engaging in such conduct which harms their professional activity and the Employer's reputation.
  • Employees also politely point out to their co-workers, clients or partners if the latter are being undignified and ask that such behaviour be stopped. If necessary, employees also notify their line manager or the management of the incident.
  • Employees use diligence, knowledge and skills in their professional activities and share them with co-workers. In order to do their best, the Employer shall ensure that employees have opportunities for self-improvement pursuant to the company's objectives.
  • Employees keep any promises they make and follow deadlines and agreements and their words are consistent with their deeds. Employees do not undertake obligations or make promises that they are unable to keep or for which they have not been authorised. Employees are not afraid to own up to their mistakes and take responsibility.
  • Employees observe internal standard job description documents to ensure consistent reliable service for clients and the ability to be supervised by the management.
  • Employees refuse any services, gifts, money and other benefits which may have an impact on their work performance or which may be construed as having an impact on their work performance. When accepting a gift in relation to work-related activities, the employee must ensure that it is not unlawful (does not constitute gratuity, accepting or intermediating a bribe, etc.). It is not permitted to use corruption, bribe and other methods distorting competition to perform work duties.

The Code of Ethics applies to all persons engaged in an employment relationship with the Employer either for a specified or an unspecified time limit as well as members of managing bodies and trainees. In the cases provided by law, ignoring the Code of Ethics may result in the termination of the contract entered into with the person who commits the above act.

Prevention of corruption

Measures of Riigi Kinnisvara AS for the prevention of corruption risks (approved on 20.06.2019)

1. Code of Ethics of RKAS (approved on 04.09.2014):

  • provides for important ethical principles imposed on employees and highlights activities that are considered permissible and impermissible;

    continuous training of employees on the subject matter, incl. upon the arrival of a new employee to the organisation through the new employee on-boarding programme, and through regular trainings for other employees. 

2. Improvement and maintenance of awareness of corruption:

  • organisation of regular (at least once a year) internal trainings on the subject matter (preparation of additional code of conduct as appropriate);

    making it easier for employees to access information on corruption (through the Intranet, newsletter, etc.).

  • The estimated maximum fixed cost for accepting and giving gifts/advantages is EUR 100. 

3. Instruction for employees on how to avoid conflicts of interest:

  • extension of the instruction to encompass the subsidiaries and Supervisory Council of RKAS;

  • explains restrictions on making of transactions with connected persons;

  • instructions on giving and receiving gifts;

  • restrictions on the use of assets for personal purposes;

  • obligation to notify of conflicts of interest;

4. Declaration of economic interests

  • members of managing bodies, members of the audit committee and certain employees are required to inform annually of any known holdings which they and connected persons (at the minimum) have in legal persons and managing bodies of legal persons;
  • in its directive No. 091 of 01.04.2016, the General Meeting of RKAS (in the person of the Minister for Public Administration) defined the Supervisory Board and Management Board members as officials using public resources, incl. as people required to submit a declaration of interests for the purposes of the Anti-Corruption Act.

5. Channels for reporting misconduct:

  • functioning anonymous hotline (e-mail and web form);
  • regular reporting;
  • agreed analysis process of tip-offs/messages.

6. General measures, the control system/environment of processes and operations, incl.:

  • principal and key support processes are described in internal procedures and instructions and available to employees;

  • coordination procedures and transparency of decision-making processes and procedures (incl. hierarchical organisational structure, collegial committees, usage of the electronic document management system);

  • implementation of the separation of functions upon making transactions/payments;

  • budgetary management;

  • approved limits (for the use of assets / proprietary rights, upon making transactions);

  • proceeding from the rent regulation;

  • determination of user rights of information systems;

  • defined business secret of RKAS and procedure for handling thereof.

7. Procurement procedures, incl.:

  • regularity of conducting procurements, approved and published procurement plans;

  • budgeting procurements, prior coordination for non-budgeted procurements;

  • as we are required to conduct public procurements, we comply with the requirements arising from the Public Procurement Act – additional implementation of an internal environment for processing procurements;

  • internal procedure for conducting procurements – activities and requirements are regulated, employees undergo regular training, requirements for procurement documents have been defined, common templates apply to procurement documents;

  • there is a requirement to ask for at least three bids in the case of procurements below the threshold value of public procurements, comparison is drawn with market prices, mandatory "four-eyes principle" applies – continuous monitoring of procurements (direct superiors, accounting) and random inspections (risk manager, legal and procurement, auditors);

  • procurement commissions – different collegial bodies across different areas of activity, minutes are taken of resolutions;

  • members of procurement commissions are required to verify their independence and the absence of a conflict of interest with regard to the parties to the procurement every time (also mandatory for external members of procurement commissions);

    agreements and arrangements which may potentially harm competition (purchases without a procurement) must be reasoned with a resolution of the procurement commission and/or separately additionally coordinated with the management.

8. Making of transactions:

  • internal procedure: coordination procedure, approval, liability, limits;

  • separation of functions (e.g. a requirement of at least two signatures, cost managers in different areas of activity);

  • deviations from standard contracts, amendments to current contracts, special agreements require a separate approval and/or a legal analysis before executing the transaction.

9. Asset management:

  • internal procedure for evaluating and deciding on investments;

  • procedures for carrying out financial transactions;

  • procedures for the movement / writing off / transfer of assets (organisation of auctions, collegial decision-making process, internal coordination procedure depending on the asset object – all the way to the Supervisory Board depending on the nature of assets);

  • protection of IT structures with organisational and technical means to prevent unauthorised persons (incl. employees) from accessing information, systems (e.g. user rights);

  • monetary limits when using assets (e.g. communications, credit cards and debit cards);

  • supervision of compensation of mission expenses of employees and monitoring of the cost budget.

10. Personnel:

  • public competitions when recruiting employees;

  • employment contracts are signed by a Management Board member;

  • prevention of subordination between employees who are related to each other or are members of the same household.

11. Rotation:

  • employees / management members should be rotated in positions with an increased risk of corruption.

12. Sponsorships:

  • collegial decision-making, the public nature of resolutions, written contracts, requirement of removal from decision-making in case of a connection.

13. Supervision carried out by managing bodies:

  • functioning audit committee;

  • risk manager function.

14. Internal audit:

  • internal audit plan approved by the Supervisory Board;

  • contracted internal audit services.

15. External audit:

  • supervision of transactions with connected parties, among others. 

Notification

The activity of Riigi Kinnisvara AS is based on the principles of integrity and transparency and we place great importance in our employees complying with ethical beliefs. One of our solutions for ensuring this is the creation of a e-mail address which can be used to send anonymous information on events that you feel are not in compliance with good business practices and generally accepted moral norms.

RKAS's employees as well as partners and third persons can use the email address on the website.

Information provided will be processed according to the personal data protection law. RKAS will guarantee the confidentiality and anonymity of the sender. 

Please consider the following before you use the tip-off channels:

  • Date of the event
  • Place of the event
  • Description of the event
  • Source of information

You can leave your contacts while sending the tip-off if you want us to give you feedback on the tip-off you sent.

Send a tip-off:

NUKU Theatre (extension completed 2016). Photo: K. Haagen