MESSAGE FROM THE MANAGEMENT

Doing business, the right way is one of our most important values at Delca Logistic UAB.

We set high standards of legal compliance and business ethics in performing our business by operating in an economically, environmentally, and socially responsible manner, as specified in this Code of Conduct.

This document guides us to put our values and commitments into practice – throughout the company and in everything we do. It helps us navigate through areas and situations where responsible conduct and ethical decision-making are critically important.

Our Code of Conduct defines the boundaries within which Delca Logistic UAB employees must act to comply with national, international laws and our internal policies.

Moreover, we expect our business partners to act in accordance with the rules of this Code of Conduct.

Thank you for upholding our values and helping us to be the best transportation service provider we can be.

Aldas Katkauskas

Chief Executive Officer

INTRODUCTION

Delca Logistic UAB has high standards for conducting business ethically and in accordance with all transportation industry standards, laws and regulations.

Delca Logistic UAB expects the same level of commitment from its employees, business partners and suppliers. This Code of Conduct (CoC) documents fundamental principles for establishing and maintaining a responsible and ethical business model at Delca Logistic UAB company.

This Code of Conduct stipulates the minimum requirements. Delca Logistic UAB employees, business partners and suppliers are expected and encouraged to take relevant measures for the content of this Code to be implemented and monitored in their own operations.

Delca Logistic UAB recognizes that implementation of the principles established in this Code of Conduct is a continuous process and acknowledges its improvement. Delca Logistic UAB expects to develop the ethical dialogue with its employees, business partners and suppliers.

ETHICAL PRINCIPLES AND CORE VALUES

At Delca Logistic UAB, our company’s core beliefs and values are the following:

• Responsibility
• Integrity
• Obedience to the law
• Respect for others
• Teamwork
• Honesty
• Accountability
• Commitment to the Code

FAIR AND EQUAL OPPORTUNITIES

At Delca Logistic UAB, we respect our employees and guarantee fair and equal opportunities to all.

Our employees shall be treated with respect and dignity, based on their individual ability and qualifications. Any form of discrimination in hiring and employment practices, on the ground of race, gender, age, religion, caste, national origin, disability, political affiliation, sexual orientation, pregnancy, family responsibilities, marital status or union membership, must not be tolerated.

Employees shall not be subject to any physical, sexual, psychological or verbal harassment or inhuman treatment nor is there to be the threat of any such treatment.

In case of fair and equal employee treatment compliance risk or infringement, employees must speak-up or report immediately.

NO RETALIATION

At Delca Logistic UAB employees who report an ethical concern in good faith cannot be subjected to any adverse employment action including:

• Unfair dismissal, demotion or suspension
• Unfair denial of a promotion, transfer or other employment benefit
• Bullying and harassment, either in person or online
• Exclusionary behavior
• Any other behavior that singles out the person unfairly

NO HARASSMENT

At Delca Logistic UAB, we practice zero tolerance on harassment for any form of harassment, including sexual harassment and bullying. We treat all our employees, customers, business partners, suppliers and other stakeholders with dignity and respect at all times.

Any type of harassment, including physical, sexual, verbal or other, is prohibited and can result in disciplinary action up to, and including, termination. Harassment can include actions, language, written words or objects that create an intimidating or hostile work environment, such as:

· Yelling at or humiliating someone

· Physical violence or intimidation

· Unwanted sexual advances, invitations or comments

· Visual displays such as derogatory or sexually-oriented pictures or gestures

· Physical misconduct including assault or unwanted touching

BULLYING

At Delca Logistic UAB, we practice zero tolerance on bullying. We are committed to ensuring that our employees, our contractors and our customers work in safe and respectful environment that is free of bullying. We consider bullying actions, such as:

· Spreading malicious rumor or gossip

· Excluding or isolating someone socially

· Establishing impossible deliverables

· Withholding necessary information or purposefully giving the wrong information

· Intimidating someone

· Impeding someone’s work

· Unfairly denying training, leave or promotion

· Sending offensive jokes or emails

· Criticizing or belittling someone constantly

· Tampering with a person’s personal belongings or work equipment

REPORTING / SPEAKING UP

At Delca Logistic UAB we practice a speak-up policy and provide a few ways for our employees to report concerns or breaches of the Code of Conduct.

Our company encourages all employees to ask questions and raise issues without fear of retaliation and is committed to treating reports seriously and investigating them thoroughly.

Our employees must report suspected unethical, illegal, or suspicious behavior immediately. The company does not tolerate retaliation against anyone who makes a good faith report of suspected misconduct or otherwise assists with an investigation or audit.

At Delca Logistic UAB, to report a concern all employees may:

· Talk to direct manager;

· Internal Sustainability group members;

CONFIDENTIALITY

At Delca Logistic UAB, we are committed to information confidentiality and employees’ obligation to uphold this standard.

Delca Logistic UAB employees maintain the confidentiality of all proprietary information. Proprietary information includes all non-public information that might be harmful to the company and its customers and business partners if disclosed.

Confidential information can include:

· Customer lists

· Supplier lists

· Pricing information

· Terms of contracts

· Company policies and procedures

· Financial statements

· Marketing plans and strategies

· Business development plans

· Any other information that could damage the company its staff, its customers, or suppliers’ businesses

CONFLICTS OF INTEREST

At Delca Logistic UAB, we avoid conflicts of interest. A conflict of interest can occur when an employee’s personal activities, investments or associations compromises their judgment or ability to act in the company’s best business interests. Our employees should avoid any types of situations that can give rise to the conflicts of interest.

Our employees must timely disclose any relationships, associations or activities that could create actual, potential, or even perceived conflict of interest to their direct manager or the Human Resources department.