Žemaitės g. 96E, LT-76196, ŠIAULIAI

Code of conduct

1. PREAMBLE
Progress, quality, efficiency and safety are the key values of the company. Being reliable and sustainable our company is developing good relationship with its employees, business partners, customers, state regulatory bodies and the public.
UAB Nostrada (hereinafter referred to as the “Company”) relates the success of its activities with trust of interested persons. To achieve its goals the Company has gathered the team of qualified experts who are constantly improving their skills, and for whom ethical conduct with colleagues, clients and partners is fundamental in their daily performance.
The Code of Conduct describes the standards which employees of the Company adhere to. Ethical and legal conduct is the basis for the behavioral standards.
Our Code of Conduct is the commitment of the Company and the document summarizing our propagated values and business principles. This is the expression of professionalism which the employees enshrine in their activities and which is expected from their partners. The commitment to follow the Code of Conduct and the rules therein is one of the key conditions for cooperation and labor relations.
The aims of our Code of Conduct are:
• To reveal and consolidate the values, business principles and behavioral standards of the Company.
• To define the fundamental principles for relations with customers, business partners, state, public and municipal institutions (their representatives), competitors, shareholders and employees of the Company.
Each our employee, having received the information about the non-compliance (violation of) with any rules, obligations or commitments of the Company as well as about any circumstances that would evidence that there exists a real threat for the interests of the Company, its employees, clients, business partners or shareholders, must report that to the head of the Company.
We respect each our client, colleague, business partner, we commit ourselves to behave respectfully and fairly to the extent that he/she has no doubts over the reliability of cooperation.
We pursue the principles of fair business. We act transparently, reliably and fairly by separating the public and private interests.
We avoid conflicts of interests i.e. situations, where an employee has to choose between the interests of the Company, its customers or private). The direct supervisor (the head of the Company) shall be always informed in the event of conflict. The pursuit of private financial interests in performance of official functions at the expense of the Company, its customers, partners or public finances is not tolerated at the Company.
Please note, that this Code of Conduct is applied to all companies of RV Transport / Nostrada group.

2. ENVIRONMENTAL PROTECTION
The Company, as a stakeholder of the responsible business, undertakes to actively reduce its environmental impact, including regular measuring and evaluation of the impact on the environment.
We endeavor that all the employees are adequately informed and trained on the issues related to the environmental requirements. Each our employee must make all possible efforts to reduce the amount of waste and any other impact on the environment.
In our activities we endeavor to save natural resources, raw materials and energy, choose our products properly and to purchase and use them in a responsible manner, manage waste and reduce its amount responsibly, support and contribute to the national initiatives on environmental protection.

3. COMPLIANCE WITH LEGAL ACTS
Compliance with the legal acts is an absolute requirement applied to the Company and its employees.
Each employee must be thoroughly aware of the legal acts regulating the performance of his/her working functions. The heads must provide their subordinates with all necessary explanations and advice in the field of application of the legal acts in performance of their working functions.
The Company is strictly committed to act in compliance with non-discriminatory and fair operational standards, protect environment and ensure safety and health of its employees.
The Company believes that the employees follow all the laws and regulations for healthcare, safety and environment; obtain all necessary permits and perform their works strictly in compliance with the requirements of appropriate legal acts.

4. WORKING RELATIONS AND PERSONAL COMMITMENTS
The relations between the Company and its employees are based on the long-lasting cooperation, mutual respect, openness and fulfilment of commitments.
The Company creates the working conditions that meet work safety requirements for each employee, puts all efforts depending on its opportunities that employees would avoid stress and feel safe with regard to their professional position in future.
At work the employees must behave business like: to behave correct, polite, comply with the rules of communication ethics and behave the way that their actions would not be detrimental to the business reputation of their Company.
During non-working hours the employees shall also avoid any such situations, where their misbehavior might not be associated with the Company and its reputation.
Politeness and helpfulness are the key principles of collegial communication. Demonstration of negative emotions, voice rise up in speaking or acts of violence against other employee (both psychological and physical) shall never be tolerated. Any type of harassment towards other person shall be strictly prohibited. Unethical, malevolent or other adverse behavior shall not remain unnoticed or unconsidered.
a. Loyalty of employees
The loyalty of employees towards the Company shall be expressed through:
• The perception of the goals and commitments of the Company by the shareholders and their proper implementation;
• Fair execution of lawful instructions by the heads, proper performance of duties;
• Clear limits of acceptable and encouraged conduct of employees dealing with customers, partners, state, public and local municipal institutions (their representatives) and shareholders of the Company;
• Protection of interests of customers, employees, business partners, society and shareholders;
• Reporting all the noticed cases of corruption or other criminal activities.
b. Discrimination
Each employee has the right to be treated fairly, collegially and respectfully by his heads, subordinates and other employees performing the same or similar duties. The members of our Company shall not tolerate any kind of discrimination and harassment (on the basis of race, religion, beliefs, ethnic origin, gender, disability, age, marital status, etc.). All the employees of the Company shall act in accordance with the Code of Conduct.
The Company shall not tolerate discrimination on political grounds, religion, sexual and private opinions as well as on marital / health situation or condition. Personal qualities (honesty, decency, etc.) and competence of the employee are the key criteria based on which the Company makes a decision on his/her employment.
c. Conflict of interest
Business transactions should be implemented to comply with interests of the Company in the best possible manner. Neither natural, nor legal person, in any relationship with the employee, may not gain benefits from the Company in the dishonest manner, using his/her connections with the employee or his/her position held.
It is necessary to avoid the situations, where the conflict of interest between the employee’s liability against the Company and his/her private interests occurs. The employee must avoid any circumstances which might cause damage to the reputation of the Company or other material and immaterial interests of the Company.
Participation in the activities of other entity, which competes with the Company, in any legal form (including investment in such entity or having any financial interest from this entity) without a written consent by the Company shall be incompatible with labor relations in the Company.
All conflict situations related to labor relations within the Company shall be resolved immediately and firmly. The Company shall not prohibit its employees to be engaged in the activities which neither has, nor might have a negative impact on the interests of the Company and proper performance of the working functions of the employee. Still, the employee must inform about them in writing prior to the start of such activities in order to avoid the conflict of interests.

5. RELATIONS WITH CUSTOMERS, PARTNERS, REPRESENTATIVES OF PUBLIC INSTITUTIONS
Our relations with customers, partners and representatives of other institutions are based on respect, integrity, professionalism, mutual trust, justice, priority of customer interests, compliance with commitments, information sharing and the priority of negotiations against legal actions.
The employees of the Company must make every possible effort to prevent any manifestations of corruption.

6. RELATIONS WITH COMPETITORS
Our relations with competitors shall be based on the principles of honesty and mutual respect.
In case of any disagreement or conflicts in entering into competitive actions, the negotiation and compromise are always a priority.
Fair competition is the fundamental principle in the performance of the Company. Information on the activities of the competitors shall be collected only by lawful and publicly available information collection means.

7. INFORMATION AND COMMUNICATION WITH THE PUBLIC
All the information on its activities the Company shall disclose strictly in accordance with the requirements of legal acts of the Republic of Lithuania and following such principles as: authenticity, regularity, operability, balance between the private and public interest.
The employees of the Company must refrain from disclosure of any information to the mass media representatives, except for such cases, where the appropriate written instruction is obtained from the head of the Company.
Information on behalf of the Company both to the mass media and any third parties that are not the customers or partners of the Company shall be provided only by the authorized person or the head of the Company.
Confidential information related to the activities of the Company and its partners shall be kept in strict secret by each employee of the Company. The employees of the Company declare their participation in political or trade, branch associations, communities and other non-governmental organizations in accordance with the procedure established in the Company.

8. BRIBERY, FACILITATION PAYMENTS, BUSINESS LUNCHES AND GIFTS
The Company shall never aim to gain business advantage by unlawful means. It shall be strictly prohibited to offer or give bribes to the third parties in the activities of the Company.
None of the employees may make any payments, give bribes, and offer unfair financial benefits to the customers or other persons implementing public functions, thus endeavoring to maintain commercial relations in providing services or obtaining other benefits.
In performance of their functions, it shall be strictly prohibited for the employees of the Company to accept any gifts, and for the customers, business partners or their representatives to give them as well as to accept money or conclude contracts for privately received reward from the latter.
The employees of the Company must not grant any hidden privileges to the customers, business partners, representatives of state or municipal, or public institutions.
The repayment with expensive gifts and all other forms of illegal payments, services or other remuneration by the employees to the customers, representatives of state, municipal or public institutions, or other third persons, which are in business relations with the Company, for the taken or non-taken decisions in favor of the Company is strictly prohibited.
An employee of the Company who suspects that any third party (customer, colleague, etc.) is trying to involve or use him/her in conclusion of unlawful transaction, must report that to the head of the Company. In case of doubts, the beneficiary should apply to (the title of an appropriate authorized person) for the advice and instructions.
Business lunches and business gifts to the employees should comply with the general policy for business expenditure and the rules and requirements of the government institution concerned or those of a legal person. The third parties shall not be involved in order to circumvent the attitudes of the aforementioned politicians.
a. Benefit provocation
The term “benefit” includes: gifts, loans, tax benefit, reward, position, employment, transaction, services, support, etc.
The Company shall prohibit for both the heads or employees to provoke any benefit from the customers, suppliers or any person related to the business of the Company.
b. Benefit acceptance
The heads and employees must refuse to accept a benefit offered on account of their position held, if the acceptance of the benefit might affect their objectivity or force them to act against the interests of the Company, or if that might result in partiality complaints.
The heads or employees (by immediately informing their head on this case) may consider and voluntarily accept the benefit provided only if:
• The benefit accepted has no impact on the performance results of the beneficiary;
• The beneficiary does not feel obliged to repay the giver by doing something for him;
• The beneficiary may openly discuss the received benefit without any reservations;
• The type (for example, promotional or agitation gift, on the occasions of holidays/celebrations) and the value of the benefit received are such that refusal to accept it is considered as non-amicable or impolite behavior.
Gifts should be of low value and granted not often.
c. Benefit offer
Any payments, agreed favorable conditions or other advantages provided by the heads or employees in performing the Company’s activities, shall comply with the Company’s prevalent practice in dealing with such issues, and they shall receive the prior written approval of the director.
d. Entertainment
Although entertainment is an acceptable form of business and public conduct, the heads or employees should refuse invitations to catering institutions or entertainments that are too often in order to avoid discomfort or loss of objectivity in performance of the Company activities. If the refusal of invitation is discourtesy, the head or employee may accept the invitation upon agreement that he/she would be allowed to respond the same way.

9. PROTECTION OF INTERESTS OF THE COMPANY, ITS SHAREHOLDERS, CUSTOMERS, BUSINESS PARTNERS AND EMPLOYEES
The Company makes all the possible efforts to protect and defend the rights and lawful interests of its shareholders, customers, business partners and employees.
The employees of the Company should take all possible reasonable actions dependent on their will in order to prevent any unlawful actions of any employee, customer, business partner or any third party, which would cause damage to the State and the public in general as well as to the Company, its customer, employee or business partner individually.
The employee of the Company must refrain from any action which would breach good character or the security of legal norms. The Company shall preserve the full confidentiality of the persons who reported the non-compliance to the norms of this Code of Conduct and ensure their protection as provided by laws.

10. USE OF INFORMATION TECHNOLOGIES
The Company shall not tolerate the use and storage of any information humiliating the honor and dignity of the person as well as any other illegal information in the in IT systems or data storage carriers of the Company.
The Company encourages the employees to use information technologies (computers, IT networks, mobile phones, e-mails and the Internet) responsibly. The employees must not forget that by using information technologies they are responsible for our information security, loss, impairment or damage of technologies.
The computer hardware located in the premises of the Company may not be used for writing of comments in the Internet (including blogs and social networks) or answering the comments of other persons.

11. CONTROL
Where the employees fail to comply with the provisions of the Code of Conduct, the Company may apply disciplinary measures, including dismissal from the office. Each employee shall receive a link to this Code of Conduct and shall acknowledge himself/herself with this Code of Conduct by reading it online. The obligation of the management is to ensure that the Code of Conduct is included into the employee training programs.
The management shall regularly monitor whether the Code of Conduct is pursued, and, if necessary, implement specific monitoring programs. The direct supervisor or the appointed authorized person shall be addressed with regard to the violations of the Code of Conduct observed. The observed violations of the Code of Conduct shall also be reported by e-mail: odeta.maksvytyte@rvtransport.lt.

12. IMPLEMENTATION
The Code of Conduct shall be implemented by all companies of RV Transport / Nostrada group.
We pursue that our suppliers, partners and their supply chain would also implement the provisions of our ethical conduct.