+370 600 54945, +370 671 86995 info@arkama.com

APPROVED
by the Director of UAB „Arkama“
March 2, 2022, Order No. II-2022-03

CLOSED JOINT-STOCK COMPANY „ARKAMA“
CODE OF ETHICS

CHAPTER I

GENERAL PROVISIONS

1. The Code of Ethics of the closed joint-stock company „Arkama“ (hereinafter referred to as the Company) (hereinafter referred to as the Code of Ethics) is a document summarizing the values and business principles advocated by the Company, as well as defining a standard of ethical and correct behavior. The employee’s (hereinafter referred to as the employee) commitment to follow the Code of Ethics and the rules contained therein is one of the essential conditions of employment with the Company.
2. The purpose of the Company’s Code of Ethics is to define and reinforce the Company’s values, standards of activity and behavior, and professional ethical norms that employees must follow in their work activities.
3. The provisions and norms of the Code of Ethics apply and are mandatory for all employees, both in the performance of their duties during working hours and in situations outside of working hours where their inappropriate behavior could be associated with the Company and its reputation.
4. The Code of Ethics is prepared in accordance with the Constitution of the Republic of Lithuania, the Labor Code of the Republic of Lithuania, the Law on Corruption Prevention of the Republic of Lithuania, and other legal acts.
5. The Company’s Code of Ethics is published on the Company’s website (www.arkama.com) and is mandatory for all entities related to the Company through business relationships (contractors, subcontractors, suppliers, buyers, sellers, etc.).

CHAPTER II

MAIN PRINCIPLES OF EMPLOYEE ETHICS

6. Main principles of employee ethics:
6.1. Respect for people. Every employee, regardless of their position, is treated fairly, collegially, politely, and respectfully.
6.2. Legality. All Company employees must be aware of and comply with legal requirements, respecting the state, its institutions, and agencies.
6.3. Non-discrimination. The Company does not tolerate any form of discrimination (based on race, religion, religious beliefs, nationality, gender, political views, disability, age, marital status, etc.).
6.4. Transparency. In case of doubt about the impartiality of decisions made or potential conflicts of interest, employees must justify their decisions.
6.5. Honesty. An employee may not use their position to benefit individuals or entities related to them at the expense of the Company.
6.6. Avoidance of conflicts of interest. Employees must avoid situations requiring a choice between the interests of the Company, its clients, partners, or personal interests. In the event of a conflict of interest, the employee must inform their direct supervisor or the Company director and refrain from issues that raise conflicts of interest. The pursuit of personal financial interests in performing work functions at the expense of the Company, its clients, partners, and public finances is not tolerated.
6.7. Responsibility. Employees’ activities are based on personal responsibility for the consequences of their decisions or results of activities, and their potential benefits or harm.
6.8. Exemplary behavior. Employees must behave impeccably and appropriately, avoiding situations where their behavior could negatively affect the Company’s reputation and authority.

CHAPTER III

INTEREMPLOYEE RELATIONS

7. The Company’s relationships with employees are based on cooperation, mutual respect, openness, and commitment fulfillment.
8. Employees must observe the following behavioral norms in relations with colleagues:
8.1. be correct, polite, and observe communication etiquette during work;
8.2. address comments to other employees personally, respectfully (without raising voice), without demeaning the dignity of others.
9. The Company does not tolerate any form of violence (psychological, physical), sexual harassment, or spreading negative information about others (gossip, slander, etc.). Such behavior is considered unethical.
10. The Company does not publicly analyze specific employees’ actions or assess personal qualities and competencies of employees.
11. Employees’ relations with the Company are based on the principles of solidarity and loyalty. Actions, statements, and comments publicly (in the media, online, etc.) criticizing the Company are considered unethical behavior. The Company encourages constructive and open relations between the Company and employees, providing opportunities for employees to express comments, requests, suggestions, and receive answers and explanations to questions.
12. Employees are encouraged to resolve disputes among themselves and, if unsuccessful, to contact their direct supervisor.
13. Employees are encouraged to help each other, share experience and knowledge.
14. Employees are encouraged not to tolerate violations or other illegal acts committed by other employees.

CHAPTER IV

CONFLICT OF INTEREST

15. Conflict of interest – a situation where an employee’s personal interests may conflict with the Company’s interests. To avoid conflicts of interest, the employee must:
15.1. not seek personal gain at the Company’s expense;
15.2. not cover personal expenses by using their position;
15.3. not pursue personal or family interests in transactions with the Company or between the Company and any supplier or client;
15.4. not engage in activities during working hours for the benefit of other persons (natural or legal);
15.5. not engage in activities that would be harmful to the Company from a competitive perspective or create a conflict of interest;
15.6. avoid any situations that could harm the Company’s reputation or other material and non-material interests of the Company;
15.7. complete and submit their private interest declarations within the timelines and procedures established by the Company.
16. An employee who encounters a conflict of interest in the Company must take active steps and promptly inform their direct supervisor and withdraw.
17. All conflict of interest situations within the Company are resolved immediately.
18. Participation in any legal form (including investment in or holding any financial interest in such a subject) of another, competing entity, without written consent from the Company, is incompatible with employment relations in the Company.
19. The Company does not prohibit its employees from engaging in activities that do not negatively affect the Company’s interests or the proper performance of the employee’s functions. To avoid conflicts of interest, employees must inform the Company director in writing before starting such activities.

CHAPTER V

GIFTS AND OTHER BENEFITS

20. A gift is any gratuitously transferred property, service, benefit, or advantageous conditions provided.
21. The Company employee must refuse to accept gifts except when gifts are for representation purposes (with state, institution, Company, and other symbols, such as pens, calendars, books, T-shirts, keychains, other souvenirs, and informational publications, etc.), and their value does not exceed 30 EUR.
22. Gifts exceeding 30 EUR, given according to international protocol and traditions, are accepted on behalf of the Company.
23. The evaluation of gifts is approximate and is conducted for the purpose of registering or not registering the gift. The approximate market price, prices of similar items, and the principle of reasonableness are considered in determining the value of the gift. If in doubt about registering or not registering the gift, the gift is registered.
24. Gifts referred to in point 22 of the Code of Ethics are registered in the gift registration journal kept in the Personnel Department (journal form attached). The person receiving the gift registers it within 5 working days of receipt. Registered gifts are the property of the Company and are stored/used within the Company.
25. If a gift is left without the employee’s knowledge and does not meet the criteria specified in points 21 and 22, the gift is returned to the person/Company who left it or destroyed under the supervision of the person responsible for corruption prevention in the Company.
26. Employees are prohibited from offering or giving any form of gift or benefit to unfairly secure an advantage or the recipient’s bias in favor of the Company.
27. The employee must report any attempt to exert illegal influence to their direct supervisor.
28. Employees reporting an internal rule violation within the company should not face threats (dismissal, retaliation, or other negative consequences) for reporting.

CHAPTER VI

COMPLIANCE WITH LEGAL ACTS

29. Compliance with legal acts is the primary requirement for the Company and its employees.
30. Every employee must comply with applicable laws and local regulatory acts and be familiar with legal acts governing their job functions.
31. Managers must provide necessary explanations and advice on the application of legal acts when performing assigned job functions if requested by employees.
32. The Company commits to adhere to non-discriminatory and fair labor standards, protect the environment, and ensure the safety and health of its employees.
33. The Company declares that it pays all applicable taxes and is committed to not concealing income and honestly managing the Company’s finances.

CHAPTER VII

USE OF INFORMATION TECHNOLOGY

34. The Company does not tolerate the use or storage of any information that degrades personal honor and dignity or any other illegal information on IT facilities and data storage media located on Company premises.
35. Employees must use computers, IT networks, mobile phones, the internet, and email responsibly.
36. When using information technology, employees are responsible for the protection of Company information, and for the loss, damage, or impairment of technology.
37. Except for individuals authorized by the Company director, Company employees are prohibited from using Company-owned computer equipment on Company premises to write comments in the online environment or respond to comments made by others.

CHAPTER VIII

PROVISION OF INFORMATION

38. To avoid damage to the Company’s reputation and ensure the reliability of the information provided, employees must refrain from providing any information to media representatives. If a media inquiry is received, the employee must politely suggest that the media representative contact the authorized Company person or the Company director.
39. Information to the mass media on behalf of the Company, as well as to any third parties who are not clients or partners of the Company, is provided only by the Company’s authorized person or the Company director.
40. The protection of the Company’s confidential information must be constantly ensured. An employee who is uncertain about the confidentiality of information must clarify it with the responsible employees before disclosing it.

CHAPTER IX

FINAL PROVISIONS

41. The Code of Ethics is approved, amended, and recognized as invalid by an order of the Company’s director.
42. All employees must familiarize themselves with and follow this Code of Ethics.
43. In cases where the employee’s behavior is not regulated by the provisions of this Code of Ethics, they must comply with ethical requirements established by other legal acts and universally recognized moral standards.
44. Violations of this Code of Ethics may be considered improper performance of duties, for which disciplinary liability may be applied under the procedure established by legal acts.
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