1. PURPOSE AND SCOPE

1.1. The purpose of the Anti-Corruption Policy (hereinafter – the Policy) is to establish the principles and requirements for creating a corruption-resistant environment and guidelines for ensuring their compliance at UAB “Fegda Group” (hereinafter – the Company) and its managed companies (hereinafter collectively referred to as the Group), ensuring that the Group’s activities and conduct meet the highest standards of reliability, integrity, transparency, and business ethics accepted in society.
1.2. The Policy is the Group’s corruption prevention document by which the Group, in fulfilling its tasks and performing its functions, undertakes to have zero tolerance for corruption, to comply with the provisions and/or requirements of international and Lithuanian anti-corruption legislation, and to publicly declare that the Group does not tolerate unethical behavior, illegal gifts, nepotism, conflicts of interest, bribery, influence peddling, abuse of office, or any other corruption-related criminal acts, corrupt environments, or forms of corruption. The Group maintains a corruption-resistant environment, systematically and in a coordinated manner manages corruption risk factors to reduce corruption risk, ensures transparent, honest, and open service delivery, increases anti-corruption awareness, and encourages active employee involvement in corruption prevention.
1.3. The Policy applies to all Group employees and members of the management board. The Group’s business partners and third parties are encouraged to follow the principles of this Anti-Corruption Policy.

2. TERMS AND DEFINITIONS

2.1. The following key terms are used in this Policy:
2.1.1. Corruption – any illegal activity related to the abuse of position for personal or another person’s benefit (e.g., bribery, offering bribes, influence peddling, nepotism, failure to perform official duties).
2.1.2. Facilitation payment – an illegal payment intended to expedite a regular process that should occur without additional fees.
2.1.3. Gift / benefit – any item of value (object, service, discount, invitation, trip, accommodation, etc.) that could influence decision-making.
2.1.4. Conflict of interest – a situation where a person’s private interests or relationships may affect the performance of their duties within the Group.
2.1.5. Business partner – a supplier, contractor, client, or any other entity maintaining business relations with the Group.
2.1.6. Whistleblower – a person reporting possible corruption violations.

3. GENERAL PROVISIONS AND PRINCIPLES

3.1. Zero tolerance – The Group does not tolerate any form of corruption, including but not limited to direct or indirect bribery, illegal lobbying, or facilitation payments. Symbolic gifts and business hospitality that comply with the limits and transparency requirements set out in this Policy are not considered corruption if they are not intended to gain unlawful advantage or influence decisions.
3.2. The Group conducts continuous corruption risk assessments, identifies critical areas, and implements preventive measures.
3.3. Internal control mechanisms (checks, audits, procedure reviews) are implemented to ensure the actual functioning of the Policy.
3.4. Decision-making is based on the principles of legality, transparency, and ethics.
3.5. In case of any conflicts between this Policy and other legal acts, the provisions of legal acts shall prevail.
3.6. Where the Policy, laws, or other regulations do not establish specific standards of conduct, the Group undertakes to act in accordance with the highest standards of reliability, integrity, and transparency accepted in society.

4. COMMITMENTS AND RULES

4.1. Prohibitions
4.1.1. It is prohibited to offer, request, accept, or mediate any form of financial benefit;
4.1.2. Facilitation payments are prohibited for any purpose;
4.1.3. Nepotism and favoritism in decisions related to recruitment, procurement, or contracting are prohibited;
4.1.4. It is prohibited to require business partners to violate this Policy.
4.2. Conflict of interest management
4.2.1. An employee facing or noticing a potential conflict of interest must inform their direct supervisor;
4.2.2. It is prohibited to use Group resources, information, or position for personal gain.
4.3. Gifts and hospitality policy
4.3.1. Only symbolic gifts not exceeding a value of 50 EUR may be accepted;
4.3.2. Gifts exceeding this amount must be declared and approved by the direct supervisor. The employee who has received or intends to accept a gift exceeding the set limit must complete the Gift Declaration Form (Annex No. 1) and submit it to the direct supervisor no later than within 5 working days. The declaration must include the value of the gift, the giver, circumstances of receipt, and the business purpose. The supervisor evaluates whether accepting the gift poses a conflict of interest and aligns with the company’s ethical principles. Gifts not approved must be returned to the giver or transferred for the company’s social purposes.
4.3.3. It is prohibited to accept gifts that could create obligations or influence decisions;
4.3.4. Business meals and events are allowed if they comply with principles of fairness and proportionality;
4.3.5. Employees are prohibited from directly or indirectly demanding gifts and/or hospitality from stakeholders and business partners.
4.4. Sponsorship and support policy
4.4.1. The Group refrains from any forms of influence – direct or indirect – and does not finance or otherwise support politicians, political parties/movements, their representatives or candidates, election campaigns, funds, or other organizations established by politicians (or related persons);
4.4.2. Philanthropic and social support is provided transparently, in accordance with approved internal rules;
4.4.3. All support must be documented and publicly disclosed. Information about provided support is announced during the annual conference, indicating beneficiaries and purposes. Detailed support information is stored in company records and made available to interested parties upon request. The Group ensures transparency and accountability of support, complying with all legal requirements for reporting and disclosure.
4.5. Business partner verification
4.5.1. The Group carefully selects business partners based on their reputation and reliability;
4.5.2. Business partners are informed about the Group’s anti-corruption principles, and, where possible, anti-corruption clauses are included in significant contracts;
4.5.3. The Group does not cooperate with partners included in official sanctions lists or those with an evidently non-transparent reputation.

5. IMPLEMENTATION, CONTROL, AND RESPONSIBILITY

5.1. Organizational structure
5.1.1. Group management is responsible for fostering an anti-corruption culture and setting a personal example.
5.1.2. Group managers (chief executives) are responsible for overseeing the implementation of the Policy.
5.1.3. When necessary, Group managers may appoint a responsible person or establish a commission to coordinate the implementation of the Policy.
5.2. Training and communication
5.2.1. Periodic anti-corruption training (at least once per year) is mandatory for all administrative employees. The Administration and Business Development Department is responsible for conducting the training.
5.2.2. New employees are introduced to the Policy within 14 days of employment through the Document Management System.
5.2.3. Various communication channels are used (intranet, email, informational notices).
5.3. Reporting system
5.3.1. Employees are encouraged to report any observed, suspected, and/or potential cases of corruption or other violations of this Policy. A confidential and secure reporting system operates:

• Email: antikorupcija@fegdagrupe.lt

5.3.2. Whistleblowers are guaranteed:

• Confidentiality and anonymity;
• Protection from retaliation or adverse consequences;
• Prompt and objective investigation of reports.

5.4. Investigations and sanctions
5.4.1. In all cases, the anonymity, safety, and confidentiality of the whistleblower and information are ensured, and measures are taken to protect them from any negative consequences. Corporate Security ensures complete confidentiality and protection of personal identity, as provided by applicable legislation.
5.4.2. Violation of this Policy is considered a serious breach of work duties and may result in consequences under the Labour Code of the Republic of Lithuania, including but not limited to termination of employment due to employee fault. Criminal acts are reported immediately to law enforcement authorities.
5.4.3. Sanctions may also be applied to business partners (contract termination, inclusion in the Group’s internal unreliable supplier list).

6. MONITORING AND EVALUATION

6.1. The effectiveness of the Policy is reviewed and evaluated at least once a year.
6.2. Regular internal and external audits are conducted to assess the effectiveness of anti-corruption measures.
6.3. The Group’s annual activity report includes information about anti-corruption activities and achieved results.
6.4. Monitored performance indicators (KPI):

• Number of reports received;
• Duration of investigations;
• Number of sanctions applied;
• Percentage of employees who participated in training;
• Number of declared conflicts of interest.

7. PUBLICITY AND TRANSPARENCY

7.1. The Policy is published on the Group’s website and internal communication channels.
7.2. Business partners are informed about the Policy and encouraged to comply with it.
7.3. The Policy is approved by the Company’s Director. By order of the Group’s management, the Policy is fully integrated into the Group’s set of local normative documents.
7.4. In case of contradictions between the Policy and applicable legal acts, the legal acts shall prevail.

8. FINAL PROVISIONS

8.1. The Policy comes into force from the date of its approval.
8.2. The Policy is reviewed at least every two years or upon changes in legislation, business environment, or identification of new risk factors.
8.3. The Head of the Administration and Business Development Department is responsible for updating and improving the Policy.
8.4. All Group employees and related persons must familiarize themselves with this Policy and comply with it.

9. RELATED LEGISLATION AND SOURCES

9.1. Law on the Prevention of Corruption of the Republic of Lithuania.
9.2. Special Investigation Service of the Republic of Lithuania “Anti-Corruption Guide for Business”.

GIFT DECLARATION FORM

Annex No. 1

1. DECLARANT’S DETAILS
Name, surname: _________________________________
Position: _________________________________
Department: _________________________________
Date of declaration: _________________________________

2. GIFT INFORMATION
Description of the gift: _________________________________
Approximate value of the gift (EUR): _________________________________
Date of receipt: _________________________________
Place of receipt: _________________________________
Circumstances of receipt (business meeting, conference, etc.): _________________________________

3. INFORMATION ABOUT THE GIVER
Giver’s name, surname / Company name: _________________________________
Position / Represented organization: _________________________________
Relationship with the company (client, supplier, partner, etc.): _________________________________

4. JUSTIFICATION FOR ACCEPTING THE GIFT
Business purpose / reason: _________________________________
Is the gift related to a specific project/contract? ☐ Yes ☐ No
If yes, specify: _________________________________
Could refusal of the gift harm business relations? ☐ Yes ☐ No
Explain: _________________________________

5. SUPERVISOR’S DECISION
Direct supervisor’s name, surname: _________________________________
Decision: ☐ Approve gift acceptance ☐ Reject gift acceptance
Comments/instructions: _________________________________

Date: _________________ Signature: _________________