Sustainability

ANTI-CORRUPTION POLICY

1. GENERAL PROVISIONS

1.1. This Anti-Corruption Policy (hereinafter referred to as the “Policy”) applies to Baltic Transline, Ltd. (hereinafter referred to as the “Company”) and all its subsidiary companies (hereinafter referred to as the “Group”).

1.2. In conducting its activities, the Group adheres fairly to the international and national laws applicable to its operations, general guidelines of good practice, sector practices, and internal regulations. Adherence to ethical business principles ensures that the Group’s activities meet the highest standards of reliability, transparency, and fairness, as well as the principles of creating a transparent environment.

1.3. The objective of the Policy is to define business ethics standards, basic guidelines for their implementation, implement corruption prevention measures, and support a Group microclimate that encourages employees performing their job functions to act fairly, responsibly, transparently, and in accordance with established behavioral rules and ethical norms.

1.4. The Policy is developed in accordance with legislation, international guidelines and recommendations defining good business ethics practices, including the Ethical Trading Initiative’s Base Code, United Nations Sustainable Development Goals, United Nations Global Compact, and others.

1.5. In conducting its activities, the Group and its employees are committed to complying with all laws of the Republic of Lithuania and other EU legal acts, the Group’s internal procedures, and other document provisions. In case of any contradictions between the Policy and other legal acts, priority is given to the legal acts and their provisions.

1.6. If there are no specific behavioral norms in both the Policy and legal acts, the Group is obliged to behave in a manner acceptable to the public based on standards of reliability, fairness, transparency, and business ethics.

2.         CORRUPTION, BRIBERY, AND GIFTS

2.1. The Group does not tolerate any employee’s attempt to obtain benefits for themselves or their close relatives at the expense of the Group, partners, or clients by abusing their position. Employees in the Group are prohibited from applying forms of corruption, bribery, or unethical business practices.

2.2. Upon observing signs of corruption within the Group or receiving a request to give or an offer to accept a bribe, an employee must immediately inform their immediate supervisor and the designated responsible person in the Company.

2.3. The Group does not tolerate any form of gifts that may be perceived as compensation or potential influence in the future, directly or indirectly. Group employees are prohibited from directly or indirectly demanding gifts from interested parties and Group partners.

3.         CONFLICTS OF INTEREST AND COMPETITION

3.1. When making decisions, Group employees must avoid conflicts of interest and behave in a way that leaves no doubt that such decisions are made objectively, avoiding conflicts between their private interests and the interests of the Company.

3.2. Group employees must inform their immediate supervisor and the Company’s HR Manager in writing about their participation in any legal form of another entity competing with the Group.

3.3. Group employees may engage in additional work or commercial activities, but in all cases, such activities must not pose a risk of disclosing or using Group confidential information, create a basis for a conflict of interest between employees and Group interests, hinder employees in performing their duties at the Company, use Company property for the interests of third parties, and otherwise violate the legitimate interests of the Company.

3.4. The Group fully complies with the requirements of applicable legislation and regulations governing competitive activities to ensure that the Group’s activities are fair in terms of competition.

4.         BUSINESS PARTNERS

4.1. The Group ensures that all procurement and sales procedures are carried out fairly and transparently in accordance with applicable laws. The Group undertakes to take action, including terminating contractual relationships if it is determined that the activities and behavior of third parties providing goods, services, or performing work for the Group violate the provisions of the Policy.

4.2. The Group collaborates only with reliable business partners, suppliers, and clients. When entering into transactions with other individuals, the Group ensures that international sanctions or other measures imposed by the European Union that restrict them do not apply.

4.3. The reliability of business partners is assessed based on social and financial obligations and professional capabilities.

5.         IMPLEMENTATION AND CONTROL PROCEDURE OF THE POLICY

5.1. The Group is concerned that all interested parties of the Group be familiar with the content of this Policy and apply its provisions. Therefore, this Policy is publicly available on the Company’s website and in the internal Document Management System.

5.2. Feedback from all interested parties (employees, clients, partners, the local community, etc.) is crucial for the Group. To obtain complete information about Policy violations and receive necessary information related to its implementation, an email inbox has been created within the Group: [email protected]. The confidentiality of the reporter’s identity is guaranteed. Access to the specified email inbox is only available to designated responsible persons in the Group: the Head of Human Resources and the Head of Quality and Sustainability.

5.3.All reports of current and possible violations of Policy provisions are treated as non-conformities and must be properly examined by persons appointed by the Company’s CEO. In case of actions indicating signs of corruption, disciplinary measures are immediately taken, including temporary suspension from current duties or dismissal from employment or termination of contractual relations with the employee or third party. The Group, without exception, always informs relevant law enforcement agencies about any identified signs of criminal activity.

5.4. The Head of Quality and Sustainability of the Group collects and summarizes the reports, questions, and complaints related to the implementation of the Policy received over the past calendar year and prepares a report on the effectiveness of Policy implementation and opportunities to improve it. The report is submitted for consideration by the Group’s management at the next management review meeting.

6.         FINAL PROVISIONS

6.1. The Policy is approved and, if necessary, amended by the decision of the Group’s management.

6.2. Anyone can submit a request for the correction of the Policy content. After evaluating this request, its circumstances, and the potential benefit to interested parties, the Head of Quality and Sustainability presents recommendations for amending the Policy to the Group’s management.

6.3. All Group employees, current and newly hired, must be familiar with the Policy and comply with its requirements. The Head of Quality and Sustainability is responsible for periodically familiarizing existing employees with the content of the Policy, and the HR department is responsible for informing newly hired employees.

6.4. The implementation of the Policy provisions cannot contradict the laws of the Republic of Lithuania and/or other applicable legal acts. Therefore, before implementing the Policy provisions, consideration is given to the legal regulatory framework, and only then the implementation of the Policy provisions is carried out.

EMPLOYMENT AND HUMAN RIGHTS POLICY

1. GENERAL PROVISIONS

1.1. This Employment and Human Rights Policy (hereinafter referred to as the “Policy”) applies to Baltic Transline, Ltd. (hereinafter referred to as the “Company”) and all its subsidiary companies (hereinafter referred to as the “Group”).

1.2. Meeting the expectations of stakeholders, including clients, employees, the public, and shareholders, is one of the Group’s top priorities. In light of this, the Group has committed to respecting human rights and preventing their violations by implementing international best practices, applying principles of fair business practices, and ensuring appropriate working conditions.

1.3. The goal of the Policy is to define the standards for employment and human rights that all Group employees are entitled to and the standards for their implementation.

1.4. The Policy is developed in accordance with international and national legal acts regulating employment and human rights, including the European Convention on Human Rights, the International Covenant on Civil and Political Rights, the Universal Declaration of Human Rights, the UN resolution on business and human rights, key conventions of the International Labor Organization, and others.

2.         HUMAN RIGHTS

2.1. The Group commits, without exception, to respect human rights as defined in international and national legal acts specified in Section 1.4 of the Policy. The implementation of human rights protection principles is mandatory in all areas of the Group’s activities.

2.2. The Group’s activities, directly or indirectly, must not negatively impact or violate human rights. Accordingly, the Group, in conducting its operations, fosters respect for human rights values and comprehensively promotes the application of human rights protection principles.

2.3. Among other things, in line with the Policy, the Group promotes a workplace free from discrimination, prohibits forced and child labor, and human trafficking, ensures fair and just remuneration and benefits, taking into account local laws, and ensures safe working conditions.

2.4. The Group aims for the application of human rights protection principles throughout the entire supply chain. Therefore, we encourage all stakeholders, including partners, suppliers, and subcontractors, to adhere to human rights protection principles. Non-compliance with human rights protection principles is considered intolerable, and business relationships with non-compliant stakeholders may be suspended and/or terminated.

3.         DISCRIMINATION AND HARASSMENT

3.1. Discrimination and derogatory treatment have no place in the Group’s operations. Every employee is entitled to a fair working environment and respectful treatment. Employee gender, age, nationality, race, language, origin, social status, sexual orientation, disability, health condition, ethnic background, religious and political beliefs, or other personal characteristics cannot be directed against the employee. Any form of harassment of employees is unacceptable, and incidents of harassment must be immediately reported to responsible persons.

3.2. The performance of Group employees is evaluated based solely on objective criteria outlined in internal performance evaluation procedures. Established criteria must meet the following requirements: measurable and/or calculable, reliable and easily verifiable, and, most importantly, understandable to employees. Accordingly, the potential or current employee’s remuneration is determined by adhering to the limits of remuneration ranges assigned to the employee’s position and following objective criteria related to the employee’s performance, competence, experience, qualification, skills, and specific knowledge.

3.3. The Group ensures that employees working under fixed-term contracts receive equal working conditions as employees working under open-ended contracts or performing similar job functions.

4.         FREEDOM OF ASSOCIATION AND COLLECTIVE REPRESENTATION

4.1. The Group respects employees’ right to collective bargaining. All Group employees are provided with the opportunity to establish or join associations related to relations between the employer and employees. Additionally, the Group ensures that no disciplinary or discriminatory actions are taken against employees seeking to join associations or exercising the right not to belong to any association, and any form of intimidation aimed at preventing the exercise of these rights is not tolerated.

4.2. The Group commits to engage in dialogue and negotiate fairly on working conditions with representatives when employees are legally represented by a recognized trade union.

5.         FORCED LABOR

5.1. The Group does not tolerate any form of forced labor. Employment relationships are initiated and terminated voluntarily. Group employees do not engage in any actions that seek to restrict the freedom of other employees. The Group does not tolerate, support, or participate in any business component related to human trafficking.

6.         CHILD LABOR

6.1. The Group strictly adheres to the minimum age requirements set by the laws of the Republic of Lithuania and does not employ individuals below the legally allowed age based on regulations governing the minimum age of employment. To ensure compliance with this Policy, an age check of candidates is conducted before hiring.

7.         IMPLEMENTATION AND MONITORING PROCEDURE OF THE POLICY

7.1. It is essential for the Group that all stakeholders, including business partners, service providers, subcontractors, and other third parties with whom Group employees communicate, are familiar with the content of this Policy and adhere to its provisions. Therefore, this Policy is publicly available on the Company’s website and internal Document Management System.

7.2. Feedback from all stakeholders (employees, clients, partners, local communities, etc.) is highly valued. To obtain full information about Policy violations and receive relevant information related to its implementation, the Group has established an email address: [email protected]. The confidentiality of the informant’s identity is guaranteed. Access to the specified email address is limited to designated responsible persons in the Group: the Head of Human Resources and the Head of Quality and Sustainability.

7.3. All reports of actual and potential Policy violations in the Group are treated as non-conformities and must be appropriately reviewed by persons appointed by the Company’s CEO.

7.4. The Head of Quality and Sustainability in the Group collects and summarizes reports, questions, and complaints related to the implementation of the Policy for the past calendar year, prepares a report on the effectiveness of Policy implementation and opportunities for improvement, and presents it for consideration by the Group’s management during the next management review meeting.

8.         FINAL PROVISIONS

8.1. The Policy is approved and, if necessary, amended by the Group’s management.

8.2. Anyone can submit a request for the correction of the Policy content. After evaluating this request, its circumstances, and the potential benefit to interested parties, the Head of Quality and Sustainability presents recommendations for amending the Policy to the Group’s management.

8.3. All Group employees, current and newly hired, must be familiar with the Policy and comply with its requirements. The Head of Quality and Sustainability is responsible for periodically familiarizing existing employees with the content of the Policy, and the HR department is responsible for informing newly hired employees.

8.4. The implementation of the Policy provisions cannot contradict the laws of the Republic of Lithuania and/or other applicable legal acts. Therefore, before implementing the Policy provisions, consideration is given to the legal regulatory framework, and only then the implementation of the Policy provisions is carried out.

CODE OF CONDUCT

1. GENERAL PROVISIONS

1.1. This Code of Conduct (hereinafter referred to as the “Code”) is applicable to Baltic Transline, Ltd. (hereinafter referred to as the “Company”) and all its subsidiary companies (hereinafter referred to as the “Group”).

1.2. The Group responsibly considers future generations and seeks to meet the needs of all stakeholders: employees, business partners, clients, and the community. This commitment should be reflected in the Group’s activities and promoted values. The provisions of this Code apply to all Group employees, members of management bodies, and individuals acting on behalf of the Group under service, consulting, or other agreements.

1.3. The aim of the Code is to define the general principles and principles of fair and ethical behavior in business and to obligate Group employees and other stakeholders representing Group interests to adhere to the provisions of the Code.

1.4. The Code is developed in accordance with international and national legal acts regulating ethical behavior in business, including international good business ethics practices and other recommended documents.

2.         FAIR TREATMENT OF EMPLOYEES

2.1. Motivated, competent, and loyal employees are essential for the effective implementation of high business ethics standards. The Group aims to be an attractive employer for existing and future employees, capable of attracting, developing, assisting in improvement, and maintaining competent, qualified, professional employees who cherish the values of the Group.

2.2. The Group is committed to creating a work environment based on tolerance and respect, where individuals are respected regardless of individual differences, abilities, or personal qualities, and their work is evaluated based on results and behavior in line with the values ​​nurtured by the Group. Results are fairly and transparently accounted for, and in cases of separation, it is done with dignity.

2.3. All Group employees, regardless of their level or nature of duties, are encouraged to communicate politely, be helpful and tidy, thus creating a productive and friendly environment and preventing conflicts and various disagreements.

2.4. The Group respects its employees, treats them fairly, and constantly invests in improving working conditions. Therefore, employees are expected to reciprocate with respect for each other, responsibility, and adequate use of resources.

3.         EQUALITY

3.1. The Group tolerates no discriminatory behavior towards any person based on race, skin color, nationality, gender, social origin, possible disability, health, sexual orientation, religious, or political beliefs. All employees are provided with equal opportunities for continuous improvement and self-expression within the organization. The efforts of employees in creating added value for the Group are evaluated based on results. The Group does not tolerate discrimination, humiliation, harassment, violence, or insults. All employees are treated with respect and fairness.

4.         HEALTH AND SAFETY

4.1. The Group makes every effort to protect the interests of employees and ensure a safe and harmless working environment. Employees are prohibited from consuming alcohol or illegal psychotropic (narcotic) substances during working hours, being under the influence of inappropriate use of them and/or drugs. Failure to comply with this provision may result in sanctions for employees following the Labor Code of the Republic of Lithuania. The Group provides safe workplaces and ensures the safety of processes, taking into account health-hazardous and dangerous factors in the working environment, and implements preventive measures.

4.2. Employees are provided with safe and healthy working conditions and are constantly improving them, ensuring the safety of work performed, taking into account health-hazardous factors in the working environment and implementing preventive measures. The Group’s working environment is governed by safety rules set by laws and internal Group regulations. Employees are periodically informed and instructed on occupational safety and health issues.

4.3. When developing occupational safety and health procedures, international and national legal acts were taken into account, as well as good international practice. However, to create a more effective system for nurturing employee safety and health, the Group encourages each employee to inform management about any identified threats to safety or unused opportunities for system improvement.

5.         PERSONAL DATA PROTECTION

5.1. The Group implements technical and organizational security measures to ensure that personal data is processed lawfully and only to the extent necessary to achieve the purposes of personal data processing. In its activities, the Group processes personal data in accordance with the General Data Protection Regulation (GDPR), the Republic of Lithuania Law on the Legal Protection of Personal Data, and other applicable legal acts.

5.2. The Group reserves the right to check, regularly review, and store all data, information, and correspondence, monitor the employee’s workplace and other premises of the Group using the communication tools provided to perform Group work functions.

6.         CONFLICT OF INTEREST MANAGEMENT

6.1. Applying a risk management-based approach, the Group pays sufficient attention to the risks arising from potential conflicts of interest and their prevention. In the event of a conflict of interest, the Group makes every effort to avoid any negative impact on the interests of clients.

6.2. Group employees are encouraged to act fairly, responsibly, selflessly, and avoid situations that could lead to conflicts of interest. Any employee wishing to work for a competing company or engage in another professional activity must inform their immediate supervisor and clarify whether such activity will cause a conflict of interest.

7.         BRIBERY AND GIFTS

7.1. The Group operates transparently and responsibly. The actions of the Group do not contradict any international or national legal provisions. The Group does not tolerate bribery, and it is unacceptable for the Group’s activities to be associated with opaque relationships with business or government institutions or their representatives.

7.2. Employees are prohibited from accepting or giving gifts, accepting or offering money, and providing other personal benefits to an interested party that could influence its decisions related to the Group’s activities. Business relationship support gifts cannot include loans, money, job offers, trips, compensation, services, or any other valuable compensation. Group employees can only accept business gifts that do not exceed the usual standards of business relations and transparency.

7.3. Given that any direct or indirect bribery is unacceptable, any proposal, promise, or acceptance of a bribe must be reported immediately to the immediate supervisor and/or Group management.

8.         ASSET PROTECTION

8.1. Employees using Group assets treat them with respect, act rationally and prudently, taking into account the interests of the Group. Group assets include not only material assets but also the ideas, creations, practical experience of Group employees, as well as the image and reputation of the Group in the market. Group-owned property is intended to achieve legitimate Group business goals.

8.2. In cases where employees are allowed to use organizational assets for personal purposes, employees must ensure that their activities do not violate the law, public order, and good morals and do not harm the organization’s business interests or waste the organization’s resources.

8.3. Only legally acquired software may be installed on computer systems and equipment used in the Group’s activities, and it may only be used for directly work-related purposes. Group employees are prohibited from downloading illegal and/or unauthorized software, media files, and other intellectual property without the permission of the copyright owner.

9.         BUSINESS AND FINANCIAL DOCUMENTS

9.1. All Group documents are prepared in accordance with the internal document preparation procedures, applicable laws, and good business practices.

9.2. Group employees are prohibited from falsifying documents, distorting or hiding their content. Group employees must ensure that all documents submitted to external institutions are accurate, precise, and submitted on time.

9.3. Documents prepared by the Group in the course of its activities are considered confidential information, so each employee must ensure the protection of confidential information.

10.     ENVIRONMENTAL CONSERVATION

10.1. Considering that the Group’s business model directly influences the environment, the Group places great emphasis on reducing negative environmental impact. The Group implements the requirements of applicable international and national laws. It applies the principles of continuous improvement to ensure the functioning of implemented management systems, including environmental management systems.

10.2. All Group employees are involved in environmental conservation processes, working together to implement activities and prevent pollution and waste generation. The Group provides all necessary conditions and allocates resources to implement the most effective solutions for minimizing environmental impact.

11.     RELATIONS WITH STAKEHOLDERS

11.1. The image of the Group is strongly influenced by good and constructive relationships with stakeholders: shareholders, employees, customers, business partners, competitors, and the public. Therefore, maintaining relationships with these stakeholders in the Group’s activities must remain professional and transparent.

11.2. Group representatives communicate timely with shareholders and provide them with relevant information about the Group’s financial condition and significant operational changes that may affect the value of their shares. The information provided to shareholders must be substantiated and verified.

11.3. The Group ensures that employees’ work is evaluated based on their performance and ethical behavior, taking timely and appropriate care of the health and safety of all employees, providing them with a secure (both materially and morally) and motivating environment.

11.4. The needs and expectations of each customer in the Group’s activities are a priority. When working with customers, the Group first strives to accurately identify customer requirements to respond as accurately and qualitatively as possible. Feedback from customers, reviews, comments, and unmet expectations are managed as potential opportunities for improving the Group’s activities.

11.5. The Group, in its activities, adheres to business ethics and expects the same from its business partners. Further collaboration is strengthened only with those business partners whose understanding of business ethics aligns with the Group’s, and joint efforts are directed towards sustainable, long-term cooperation.

11.6. The Group actively monitors the surrounding competitive environment. It legally and ethically collects and analyzes information about competitors, evaluates their strategic decisions. Understanding competitors allows for more effective utilization of market opportunities. In the Group, competitors are also considered stakeholders because circumstances may turn a competitor into a business partner tomorrow.

11.7. The Group ensures timely response to any requests from regulatory authorities and provides them with all necessary information, taking into account their comments. The Group also makes significant efforts to maintain good relations with the supervisory institutions of the countries where employees are on assignment.

11.8. The Group’s activities may affect not only the surrounding environment but also the community. In carrying out its activities, Group representatives always consider feedback, comments, and take them into account. When making decisions, they strive to become reliable partners and active participants in community life.

12.     IMPLEMENTATION AND CONTROL PROCEDURE OF THE CODE

12.1. The Group is concerned that all interested parties of the Group, such as business partners, service providers, subcontractors, and other third parties with whom Group employees communicate, are familiar with the content of this Code and apply its provisions. Therefore, this Code is publicly available on the Company’s website and in the internal Document Management System.

12.2. Feedback from all interested parties (employees, customers, business partners, the local community, etc.) is crucial for the Group. To obtain comprehensive information about violations of the Code and to receive relevant information related to its implementation, an email box has been created in the Group: [email protected]. The confidentiality of the reporter’s identity is guaranteed. Only designated responsible persons of the Group have access to the specified email box: the Head of Human Resources and the Head of Quality and Sustainability.

12.3. All reports of existing and potential violations of the Code’s provisions in the Group are treated as non-compliance and must be properly examined by individuals appointed by the General Director of the Company.

12.4. The Head of Quality and Sustainability in the Group collects and summarizes reports, questions, and complaints related to the implementation of the Code for the past calendar year and prepares a report for Group executives on the effectiveness of Code implementation and opportunities for improvement. The report is submitted for consideration by Group executives during the next management review meeting.

13.     FINAL PROVISIONS

13.1. The Code is approved and, if necessary, amended by the Group’s management decision.

13.2. Any person can propose a correction to the content of the Code. After evaluating this need, its circumstances, and the potential benefit to interested parties, the Head of Quality and Sustainability provides recommendations for amending the Code to the Group’s management.

13.3. All Group employees, current and newly hired, must be familiar with the Code and comply with its requirements. The Head of Quality and Sustainability is responsible for periodically familiarizing existing employees with the content of the Code, and the HR department is responsible for informing newly hired employees.

13.4. The implementation of the Code’s provisions cannot contradict the laws of the Republic of Lithuania and/or other applicable legal acts. Therefore, before implementing the provisions of the Code, the legal regulatory framework is first considered, and only then the implementation of the Code’s provisions is undertaken.

MANAGEMENT SYSTEM POLICY

„BALTIC TRANSLINE“, Ltd. – international cargo transportation and forwarding company providing comprehensive logistics services. The company’s cargo transportation network is expanded in Western Europe, the Baltic States, Scandinavia, and CIS countries. The company serves clients who are both market leaders and emerging businesses. We demonstrate our reliability through a long-term successful partnership.

MISSION – solving all customer logistics tasks and proposing professional and innovative solutions.

VISION – global logistics partner.

Our organization’s employees understand that we are responsible for providing high-quality services, ensuring a safe and healthy work environment, and contributing to environmental protection, as the company’s activities will have an impact on both the present and future environment. We take responsibility and commit to these principles:

Focus our activities on comprehensive satisfaction of customer needs and expectations.

Build long-term, mutually trusting relationships and collaboration with partners, based on knowledge sharing.

Apply continuous improvement and pollution prevention principles in company operations. Modernize and enhance existing technologies used for logistics services, taking into account technological advancements, customer needs, the activities of other stakeholders, and potential environmental impact.

Continuously monitor, control, and improve the company’s integrated management systems, encompassing the implementation of quality, environmental, occupational health and safety, and good distribution practices for medicinal products. Ensure effectiveness in meeting customer needs and surpassing their expectations, applying circular economy principles, and sustainably using natural resources.

Ensure that the company’s activities comply with the laws, regulations, instructions, and necessary permits relevant to quality, environmental protection, occupational health and safety, and the good distribution practices of medicinal products in the Republic of Lithuania and the European Union.

Strive to shape an organizational culture in which each employee, within their competence, takes responsibility for the quality of work, quality improvement, employee safety and health, and environmental protection.

Pay special attention to employee safety and health during operations and seek to minimize negative environmental impact by rational use of tools and technologies, constantly exploring effective, new work methods, technologies, equipment, and materials.

Establish an integrated management system that includes objectives for implementing quality, environmental protection, occupational health and safety, and good distribution practices for medicinal products. Allocate necessary resources to achieve these objectives.

Inform the public, government institutions, and other stakeholders about the activities carried out by UAB “Baltic transline.”.