CODE OF CONDUCT OF ACME GRUPĖ
APPROVED
by the minutes of the Management Board of
UAB “Acme grupė” meeting dated 13-03-2026
1. INTRODUCTION
The Code of Conduct of Acme grupė provides guidelines to help us implement Acme grupė values and
ensure adherence to the internal rules of Acme grupė and highest standards of business ethics in
practice. This allows us to develop long term relationships with our customers and partners, to ensure
the quality of goods and services, to encourage the best employees.
This Code of Conduct applies for all employees of Acme grupė, as well as for the members of the
Management Board and managers (hereinafter- Emploees). If you have any questions or think that
certain actions could be incompliant with the guidelines provided in this Code of Conduct, do not be
silent and seek advice from your supervisor. We want to hear from you, build trust and create a
transparent business environment together.
This Code of Conduct applies, to the extent specified herein, not only to employees of the Acme grupė
but also to Third Parties, including partners representing Acme grupė companies, as well as customers
and suppliers.
In conducting their business activities, Third Parties are required to familiarize themselves with this
document and to comply with and implement the principles of this Code of Conduct to the extent
applicable to Third Parties as set out herein.
Where a Third Party applies its own internal policies or rules, such policies or rules must be at least
equivalent to the principles contained in this Code of Conduct and must apply to no lesser extent than
required of Third Parties under this document.
The Acme grupė expects Third Parties to maintain appropriate controls and procedures to ensure
compliance with this Code of Conduct or equivalent internal policies and to be able to demonstrate
such compliance or provide evidence thereof to the responsible employees of the Acme grupė upon
request.
The Acme grupė acknowledges that this Code of Conduct cannot anticipate or define every situation
that Third Parties may encounter. Accordingly, Third Parties remain responsible for exercising sound
judgment and making properly considered decisions. In cases of uncertainty regarding appropriate
professional conduct, Third Parties should, where necessary, seek guidance from the responsible
employees of the Acme grupė.
2. ACME GRUPĖ VALUES
2.1. Accountability
We value independent, enterprising responsible and trustworthy co-workers who meet their agreed
obligations and seek to reach the highest goals of the organisation and fulfil desires of our customers.
We provide opportunities and allocate resources for making daring decisions.
Recognizing our responsibility to stakeholders, we are committed to transparency and regularly
communicate our financial and non-financial performance, as well as our progress and achievements.
2.2. Trust
We create working environment in which the best people could work and excel. We celebrate victories
and achievements together. We encourage one another to work in teams, collaborate and consult
while looking for the best solutions. We are reliable partners for our clients and co-workers. We look
forward to long term partnerships and affections both with and outside of the organisation.
2.3. Open-minded and evolving
We are professionals in the fields we operate, having open-minded, holistic, and flexible approach. We
dare to discover and try out new opportunities which are being presented by our people or observed
in a constantly changing business environment. We meet challenges while focusing onto the future
and constantly improving ourselves.
Applicable to Third Parties
The Acme grupė expects Third Parties that establish business relationships with the Acme grupė
and/or provide services in connection with the Acme grupė to uphold values consistent with those of
the Acme grupė. This includes acting responsibly and with integrity, honoring their commitments,
fostering transparency, trust and long-term cooperation, embracing innovation, and adopting a
flexible and solution-oriented approach when addressing challenges.
3. ACME GRUPĖ BUSINESS ETHICS
3.1. Fair competition
Applicable to Group Employees
Acme grupė promotes free and fair competition. The competitive advantage of our goods and services
is created over time by ensuring the highest standards of business ethics in our relationships with
competitors. We do not perform any acts which could restrict competition in the market, or which
could give an impression that our actions are unlawful or unfair.
Examples of prohibited conduct include agreeing with competitors about prices, allocation of
customers or markets, restrictions on trade, sharing sensitive information about Acme grupė pricing
or costs with competitors, conduct aimed at harming a competitor. We also apply the principles of fair
competition when cooperating with partners, therefore, we do not perform any actions aimed at
agreeing about resale prices or at entering into a business arrangement to refuse to work with certain
undertakings, with the purpose of harming them.
Applicable to Third Parties
Third Parties that maintain business relationships with the Acme grupė and/or provide services in
connection with the Acme grupė must comply with the principles of fair competition and refrain from
any conduct that may restrict free competition or violate applicable competition laws and regulations.
Examples of inappropriate conduct by Third Parties include entering into written, verbal, formal, or
informal arrangements with competitors or other market participants regarding the fixing of prices for goods or services, market allocation, refusals to deal with specific entities, or any other practices intended to distort, restrict, or prevent competition.
Such conduct may also include the disclosure to competitors of sensitive or confidential information
relating to the Acme grupė business activities, including information concerning privately negotiated
agreements, commercial terms, transactions, business strategies, or other commercially sensitive
information.
3.2. Prohibition of corruption
Applicable to Group Employees
Acme grupė does not tolerate corruption and takes preventive measures in order to prevent
manifestation of corruption and combat it. Our organisation understands corruption as a conduct of a
person, which abuses the authorisations given to such person, the standards of conduct established
by law or the internal rules of Acme grupė, for private gain of oneself or other persons and thus causing
damage to the interests of others. Corruption also includes bribery, trading in influence and other
criminal offenses of similar nature.
In our business, we are guided by the requirements regarding prevention of corruption established
under national laws and under international standards, including the U.S. Foreign Corrupt Practices
Act and the UK Bribery Act 2010. A responsible employee is appointed at group and/or company level
who oversees implementation of measures aimed at prevention of corruption at Acme grupė and its
companies.
Employees are prohibited from engaging in any acts which are indicative of corruption, accepting,
giving or offering a bribe, or otherwise engaging in any acts that could reasonably give an impression
or raise suspicions that an act indicative of corruption is being committed. Bribe is any unlawful or
unjustified reward expressed in the form of any personal benefit for oneself or for another person
(whether tangible or intangible, with or without an economic value in the market) in exchange for a
desired lawful or unlawful act or omission of another person in exercising his / her powers.
Upon having noticed any signs of corruption at Acme grupė or upon having received a request to offer
or accept a bribe, an employee must immediately inform his / her immediate supervisor. More
information on prevention of corruption is provided in the Corruption Prevention Policy of Acme
grupė.
Applicable to Third Parties
In the course of maintaining business relationships with the Acme grupė and/or providing services in
connection with the Acme grupė, Third Parties are prohibited from engaging in any conduct that could
create the appearance of, or constitute, corruption or bribery for the benefit of the Acme grupė, or
for their own benefit while acting on behalf of, or using the name of, the Acme grupė.
When representing or acting on behalf of the Acme grupė, Third Parties should refrain from offering,
giving, soliciting, or accepting gifts, hospitality, favours, or other benefits, particularly where such
conduct involves individuals who hold, have held, or may influence decision-making positions in the
public or private sector.
The Acme grupė also expects Third Parties to comply with, or apply equivalent principles to those set
out in, applicable anti-corruption laws and internationally recognised standards, including the U.S.
Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010.
Third Parties who become aware of any actual or suspected corruption or bribery in connection with
their cooperation with, or representation of, the Acme grupė must promptly report it by email to
compliance@acme.lt.
3.3. Gifts and hospitality
Applicable to Group Employees
Pursuant to established traditions and customs, it is common business practice to give gifts and show
hospitality in certain cases to customers, suppliers, intermediaries and other business partners without
expecting to receive any consideration in return. However, we understand that gifts and hospitality
may be used to disguise acts of corruption or bribery. Acme grupė seeks to ensure that gifts and
hospitality (including participation in business lunches, dinners, official events) would be accepted and
provided only in good faith, openly, fairly and without any disguised purposes.
Acme grupė employees may accept and give official business gifts of low value if they are provided for
representational purposes, in line with international business etiquette, traditions, or customs, and
accept or show hospitality of low value. Gifts or hospitality are deemed of low value if they do not
exceed EUR 100 (including VAT). In case of any doubts as to whether it is allowed to accept a gift or
hospitality offered, an employee has to contact his / her immediate supervisor.
Gifts and hospitality with a value of more than EUR 100 (including VAT) may be accepted and provided
/ shown by Acme grupė only in cases where the value of a gift or hospitality is proportionate and
appropriate for establishing new or improving existing business relationships. An employee needs to
immediately contact his / her immediate supervisor regarding the acceptance of such gift or
hospitality.
Employees are prohibited from accepting and giving gifts, or accepting and showing hospitality if this
could affect business transactions between Acme grupė and the person giving (or receiving) the gift,
potentially cause a conflict of interest, influence decisions, create obligations or raise reasonable
suspicions of the possibility of such influence.
Our organisation does not in any cases give any gifts or show any hospitality to politicians, state or
municipal officials, other civil servants or persons considered equivalent to civil servants or their close
relatives, if such action is related to the official position or the official duties of the politician, the officer
or the civil servant. Gifts or hospitality cannot be given or accepted during public procurement, other
tenders or negotiations, which would lead to a conflict of interest.
We do not accept or give gifts in cash or in other monetary values, for example, such as gift vouchers,
gift coupons, discount cards, etc.
More information on prevention of corruption is provided in the Corruption Prevention Policy of Acme
grupė.
Applicable to Third Parties
The Acme grupė expects Third Parties to maintain clearly defined and formalized policies and
procedures governing gifts and hospitality, and to ensure that such policies are implemented and
adhered to not only in form but also in practice.
The Acme grupė further expects that, when maintaining business relationships and cooperating with
the Acme grupė, representing the Acme grupė, or acting on its behalf, Third Parties will comply with
gift and hospitality standards that are equivalent to those applicable to Group Employees, as set out
in Section 3.3. “Applicable to Group Employees.”
3.4. Confidential information
Applicable to Group Employees
Each of us has an obligation to protect the confidential information of Acme grupė and to take all
necessary precautions to ensure the secrecy and integrity of such information. Information about
Acme grupė customers, partners and employees, the terms and conditions of contracts concluded by
Acme grupė, as well as any other non-public information about Acme grupė activities is considered
confidential. In case of any doubts as to whether certain information is confidential, it must be treated
as confidential until otherwise specified by an immediate supervisor. Confidentiality obligations will
remain in force for employees even after termination of employment at Acme grupė.
Employees can disclose confidential information of Acme grupė only to their supervisors or other
co-workers who have a right to access it. Confidential information of Acme grupė can be disclosed to
third persons only upon instruction of Acme grupė. In such cases, it is required to conclude a
confidentiality agreement before starting a relationship with such partner.
Applicable to Third Parties
The Acme grupė expects Third Parties to manage confidential information honestly, responsibly, and
with due care, including information relating to the Acme grupė, and to ensure the protection of trade
secrets and other confidential information.
Third Parties are prohibited from disclosing any confidential information relating to the Acme grupė
business activities, operations, or transactions to unauthorized third parties without the prior consent
of the Acme grupė.
3.5. Data Protection and Information Security
Applicable to Group Employees
The Acme grupė is committed to processing and safeguarding personal data in compliance with
applicable data protection laws and regulations, thereby ensuring the security and privacy of
customers’ and employees’ personal data.
The Acme grupė places significant importance on the protection of personal data and continuously
strengthens its information security management systems to prevent potential data breaches and
cyber threats. To achieve this, the Acme grupė implements appropriate technical and organisational
security measures, conducts regular risk assessments, provides employee training, and applies
recognised best practices and security standards.
Applicable to Third Parties
Third Parties must comply with all applicable data protection laws and regulations and implement
appropriate measures to ensure the protection of customers’ and employees’ personal data, including personal data to which they may have access through their cooperation or other business relationships with the Acme grupė.
To minimise the risk of personal data breaches, unauthorised access, or data theft, Third Parties are
expected to continuously improve their data protection and information security practices and to
provide their employees with appropriate training and awareness regarding the importance of data
protection and information security.
3.6. Property and assets
Applicable to Group Employees
We expect that every employee will protect the property of Acme grupė, will take care of Acme grupė
premises, office equipment and other available assets. All property of Acme grupė is important to the
development of our business. We use Acme grupė property only in accordance with legal requirements and in line with Acme grupė internal procedures. We must treat the property entrusted to us by our business partners and customers as responsibly as we treat Acme grupė property.
Acme grupė employees are required to protect the intellectual property of the organisation, to use it
responsibly, and to take all necessary measures to ensure its protection. Additionally, we respect the
rights of others and therefore we do not in any case engage in any unlawful activities aimed at
exploiting the assets or intellectual property of others.
Applicable to Third Parties
The Acme grupė expects Third Parties that maintain business relationships with the Acme grupė or
act on its behalf to respect and protect the Acme grupė assets and resources. This includes the
responsible use and safeguarding of the Acme grupė intellectual property and other proprietary rights
relating to its business activities, products, and services.
Applicable to Group Employees
We understand that environmental and natural resources are limited, so we aim to contribute to the
creation of a sustainable society. We make day-to-day business decisions taking into account their
potential impact on the environment, and we strive to develop Acme grupė activities and business
processes in a way that that minimizes their negative impact on the environment and supports the
achievement of environmental sustainability objectives.
Measures implemented by the Acme grupė to reduce the environmental impact of its operations
include integrating circular economy principles into its business activities, seeking to reduce the
consumption of materials and the generation of waste wherever possible, and promoting the reuse
and recycling of resources.
The Acme grupė also strives to limit the volume of products placed on the market that cannot be
repaired or whose repair is not economically viable, encourages users of its real estate properties to
choose alternative and more sustainable modes of transport when travelling to and from its premises,
invests in biodiversity management and enhancement initiatives, and undertakes other actions aimed
at supporting environmental protection and sustainability objectives.
Acme grupė is committed to complying with environmental legislation. We encourage employees to
contribute to the initiatives which would implement the principle of sustainability in Acme grupė
culture and day-to-day operations.
Applicable to Third Parties
The Acme grupė expects Third Parties to comply with applicable environmental laws and regulations
and, when designing their business models and processes, to consider the potential environmental
impact of their decisions. Third Parties are encouraged to adopt more sustainable practices and
solutions that minimize adverse environmental effects.
The Acme grupė also expects Third Parties to contribute to the promotion of sustainable business
practices and a culture of environmental responsibility by participating in initiatives aimed at
protecting, preserving, restoring, and improving the environment.
4. ACME GRUPĖ TRADE & SANCTIONS COMPLIANCE
4.1. Sanctions compliance programme
Applicable to Group Employees
Acme grupė ensures that its relationships with business partners and obligations undertaken under
commercial agreements do not violate any applicable financial sanctions, export controls or other
restrictive measures imposed by the United Nations Security Council, the European Union, the Office
of Foreign Assets Control of the US Department of the Treasury, the US Department of State, the
Bureau of Industry and Security of the US Department of Commerce and Her Majesty’s Treasury’s
Office for Financial Sanctions Implementation of the United Kingdom.
Acme grupė has adequate controls and systems in place to perform sanctions screening. More
information on sanctions compliance is provided in the Business Partner Verification Procedure of
Acme grupė.
Applicable to Third Parties
Third Parties must ensure that, upon entering into business relationships with the Acme grupė, they
comply with and effectively implement all applicable national and international sanctions
requirements, including economic and sectoral sanctions, as well as export control regulations.
Third Parties must maintain appropriate measures to ensure that the Acme grupė is not directly or
indirectly involved, including through intermediaries or other third parties, in sanctions circumvention
or evasion schemes, or in transactions that present an elevated risk of sanctions violations. Third
Parties must refrain from any conduct that could reasonably create the impression, or give rise to
suspicion, that the Acme grupė is failing to comply with applicable international sanctions
requirements.
Examples of prohibited conduct include providing goods or services in the name of, on behalf of, or for
the benefit of the Acme grupė to sanctioned persons or entities; directly or indirectly supplying,
transferring, or making available Acme grupė goods or services to sanctioned countries, territories, or
regions; supplying to the Acme grupė goods or services that are subject to import or export restrictions
in violation of applicable laws; or facilitating prohibited re-export transactions.
The Acme grupė expects Third Parties to implement and comply with all applicable sanctions, export
control restrictions, and other restrictive measures imposed by, among others, the United Nations
Security Council, the European Union, the U.S. Department of the Treasury’s Office of Foreign Assets
Control (OFAC), the U.S. Department of State, the U.S. Department of Commerce’s Bureau of Industry
and Security (BIS), and His Majesty’s Treasury Office of Financial Sanctions Implementation (OFSI) of
the United Kingdom.
4.2. Trade compliance programme
Applicable to Group Employees
Acme grupė does not enter into relationships or undertake any obligations to business partners which
are engaged in activities related to weapons of mass destruction, including any activities related to the
design, development, production or use of nuclear weapons, materials or facilities, missiles or the
support of missile projects, chemical or biological weapons.
In addition, Acme grupė does not engage with business partners whose activities are related to
terrorism, military end uses in or connected with certain government owned or controlled
corporations of such countries as identified by the US and other applicable government licensing
authorities, or exploration or production of oil and gas in Arctic, deep water (greater than 500 feet), or
shale formations in Russia or in, by, or with Russian companies, territories or any other entities as
identified by the Office of Foreign Assets Control of the US Department of the Treasury or the Bureau
of Industry and Security of the US Department of Commerce.
Acme grupė does not provide any goods or services directly or indirectly through a third party to
business partners residing or established in prohibited countries or a prohibited country’s Embassy or
Consulate, regardless of its location. The prohibited countries include Cuba, Iran, North Korea, Sudan,
Syria, Crimea Region and in regards to certain sanctioned entities – Russia, Belarus, Venezuela, as well
as any other countries sanctioned under applicable financial sanctions and other restrictive sanctions
lists.
Applicable to Third Parties
When representing the Acme grupė, Third Parties must ensure that they do not, directly or indirectly
through other third parties, establish business relationships on behalf of the Acme grupė with business
partners engaged in activities described in Section 4.2, “Applicable to Group Employees.”
Third Parties are also responsible for ensuring that Acme grupė products or services are not sold,
supplied, transferred, exported, re-exported, or otherwise made available to entities incorporated,
established, or resident in restricted countries, or for use in such countries.
Restricted countries include Cuba, Iran, North Korea, Sudan, Syria, the Crimea region, and, in certain
circumstances, Russia, Belarus, and Venezuela. This restriction also applies to any other countries,
territories, persons, entities, or organisations subject to applicable financial sanctions or other
restrictive measures.
4.3. Red flags
Applicable to Group Employees
Acme grupė looks for any red flags indicating that a commercial agreement is potentially destined for
a restricted end-use, end-user, or to a restricted destination:
4.3.1. Place
• Business partner’s branch is located abroad in a non-prohibited country, but the business
partner itself is headquartered in a prohibited country
• Delivery dates are vague, shipping routes are circuitous, final destination is a traditional
transhipment point
• Business partner uses a PO Box or UPS Store as their delivery address
• Freight forwarder is listed as the product’s final destination or business partner has indicated
they will use a freight forwarder
4.3.2. Purpose
• An export license issued by the US Government may be required for sales to business
partners buying Acme grupė products or services
• Business partner or purchasing agent is reluctant to offer information about the end-use of
the item
• Product’s capabilities do not fit the business partner’s line of business
• Business partner is unfamiliar with the product’s performance characteristics but still wants
the product
• Business partner is a freight forwarder or general trading company located in a traditional
transhipment point
4.3.3. Product
• Product requires export or import licence (e.g., products with advanced encryption
capabilities, etc.)
• Item ordered is incompatible with the technical level of the country to which it is being
shipped, such as semiconductor manufacturing equipment being shipped to a country that
has no electronics industry
4.3.4. People
• Any involvement with a person on a government denied party list, or a person in a prohibited
country (e.g., Iran), or a prohibited country bank
• Business partner’s name contains wording of a prohibited country within the name
(e.g., Syrian Airlines)
• Business partner uses a Government bank of a prohibited country (e.g., Bank of Saderat’s
Paris branch office)
• Business partner is willing to pay cash for a very expensive item when the terms of sale would
normally call for financing
• Business partner asks to omit or change information from invoices
• Business partner requests anonymity or is unwilling to provide documents to verify identity
• Routine installation, training, or maintenance services are declined by the business partner
Applicable to Third Parties
The Acme grupė expects Third Parties, when maintaining business relationships with or representing
the Acme grupė, to remain vigilant to the circumstances described in Sections 4.3.1–4.3.4 of this Code
of Conduct, as well as any similar or additional indicators that may give rise to concerns that goods
acquired through cooperation with the Acme grupė may ultimately be intended for an end use, end
user, or destination that is subject to sanctions, export controls, or other restrictive measures.
5. ACME GRUPĖ BUSINESS RELATIONSHIPS
5.1. Relationships with partners
Applicable to Group Employees
At Acme grupė, we aim to become a trusted partner to our customers. We strive to build long-term
and meaningful relationships, and we want our customers to be satisfied with the goods and services
that Acme grupė provides. Each one of us is responsible for the creation of a positive customer
experience and the strengthening of Acme grupė brand and reputation.
We treat our customers fairly and respectfully, and we help them find the best solutions. We try to
understand the demands and expectations of our customers and we are always open to customer
feedback regarding the work of Acme grupė. We effectively respond to customer complaints and take
steps to improve Acme grupė work quality.
We maintain our relationships with suppliers and other business partners based on the standards of
business ethics, mutual trust and transparency. We choose our partners upon evaluating objective
criteria such as quality, reliability and price.
Before deciding to enter into a relationship with clients and business partners, we conduct a due
diligence process. In any cases, we never choose our clients and partners for the purpose of placing
our own personal interests or goals.
More information on relationships with business partners is provided in the Procedure of Due Diligence
of Business Partners of Acme grupė.
Applicable to Third Parties
The Acme grupė expects Third Parties, in conducting their business activities, to adhere to the
principles of mutual trust and transparency. When representing the Acme grupė, they are also
expected to uphold the same values by acting honestly and respectfully, focusing on the needs of
business partners, striving to meet their expectations, and providing goods and services in accordance
with the highest standards.
In organising their activities, Third Parties must also ensure compliance with fair competition and anticorruption requirements and implement international labour law and human rights standards. Where required, Third Parties are expected to comply with our internal policies and undertake confidentiality obligations.
5.2. Cooperation with institutions
Applicable to Group Employees
Acme grupė complies with all legal requirements related to the cooperation with competent
authorities and civil servants, including anti-corruption and lobbying legislation. When cooperating
with competent authorities, we aim to maintain good relationships with them. For this purpose, any
communication with authorities must be agreed in advance with the relevant manager of Acme grupė
company to ensure that the information provided to authorities is entirely accurate, reliable and
correct.
We ensure proper conditions for the representatives of competent authorities to supervise and inspect
the activities of Acme grupė. We respond to inquiries and requests in a timely and appropriate
manner. In case any discrepancies are identified in regards to Acme grupė operations, we take
immediate action to remedy such discrepancies and ensure that they do not recur in the future.
Applicable to Third Parties
The Acme grupė expects Third Parties to ensure compliance with applicable legal requirements in
relation to cooperation with competent authorities and the provision of relevant information in the
course of their business activities.
The Acme grupė also expects that, where competent authorities identify non-compliance issues or
deficiencies that may have a material impact on cooperation with business partners, including business
relationships with or representation of the Acme grupė, the Acme grupė will be informed thereof and
that such deficiencies will be remedied without undue delay. Appropriate preventive measures should
also be implemented to avoid similar situations in the future.
5.3. Responsibility to society
Applicable to Group Employees
Acme grupė seeks to develop socially responsible business. For this purpose, we contribute
gratuitously to the general welfare of society, support certain social projects. When providing charity
and sponsorships, we always comply with the requirements of legal acts and the provisions of the
Corruption Prevention Policy of Acme grupė. Summarised information about our charity and
sponsorships of significant value is made publicly available in order to ensure the transparency of the
funding provided.
Our organisation does not in any way fund or support political parties or political campaigns. The
recipients of charity or sponsorship may not be government representatives making decisions related
to the interests of Acme grupė. We never provide tobacco or its products, ethyl alcohol or alcoholic
beverages or any items subject to restrictions for circulation in the market for charity or sponsorship
purposes.
More information on provision of charity and sponsorships is provided in the Corruption Prevention
Policy of Acme grupė.
Applicable to Third Parties
The Acme grupė expects Third Parties to uphold the same values, conduct their activities in a socially
responsible manner and, when providing charitable donations or support, ensure financial
transparency.
The Acme grupė also expects Third Parties to avoid any prohibited or non-transparent financing of
political parties or charitable organizations, involvement with charitable organizations that may raise
concerns, or any similar activities that may have a negative impact on the Third Parties themselves,
the Acme grupė, or transactions between them.
5.4. Conflicts of interests
Applicable to Group Employees
A conflict of interests is any situation, where private interests of Acme grupė employee may conflict
with Acme grupė interests. At Acme grupė, we prevent situations where the ties to Acme grupė
employee’s family, relatives or friends, or activities or membership in political activities, other
workplaces, whether profit or non-profit, religious or charitable organisations, could affect decisions
made on behalf of Acme grupė or cause damage to Acme grupė assets or reputation.
If employee’s personal ties or activities cause or could cause a conflict of interest in decision-making
on behalf of Acme grupė company, such employee has to inform his / her immediate supervisor in
advance, withdraw from and do not further participate in the consideration or adoption of the
decision.
In any case, employees are prohibited from seeking private gain at the expense of Acme grupė,
covering personal expenses by using their working position at Acme grupė, pursuing personal interests
in transactions with Acme grupė or in transactions between Acme grupė and any business partner or
customer, hiring family members to work at Acme grupė in positions of subordination, working for the
benefit of other workplaces or individuals during work at Acme grupė, using Acme grupė assets, name
or reputation for private gain, engaging in activities that would be competitively detrimental to Acme
grupė, including investing in or having other financial interests from Acme grupė competitors.
For the purpose of ensuring transparency, all managers of Acme grupė are required to fill in
declarations of private interests and to disclose in them the personal or financial interests that may be
important to the performance of work duties. Access to such data is made available only for relevant
managers, the employee/employees responsible for the prevention of corruption, and the Head of
Legal Unit. In case of changes in data, the declaration or private interests is updated.
Despite the measures in place at Acme grupė, practical situations may occur where in case of a conflict
of interest, we will not be reasonably satisfied that all significant risks to Acme grupė customer or
business partner will be prevented. In such case, we must clearly disclose the information about the
conflict of interest to such customer or business partner before entering into or continuing a
relationship.
Applicable to Third Parties
Third Parties must ensure compliance with conflict of interest management principles. The Acme
grupė expects Third Parties, when maintaining business relationships with or acting on behalf of the
ACME grupė, to avoid any situations that may give rise to an increased risk of a conflict of interest due
to personal interests, relationships with parties involved in a transaction, or other circumstances.
Where Third Parties are aware that the nature of another party or the services provided may give rise
to a conflict of interest, they must take appropriate measures to manage such risk, for example by
informing the relevant parties, including the Acme grupė, of the potential conflict of interest risk,
refraining from communications relating to the negotiation of transaction terms, or taking other
measures necessary to manage the situation.
5.5. External communication
Applicable to Group Employees
Each Acme grupė employee represents and forms an impression about Acme grupė when
communicating in public or on social media as a specialist in his / her field. We hope that all
communication will be conducted in accordance with Acme grupė values and this Code of Conduct,
and that our partners, customers, journalists and competent authorities will be able to form a positive
image of Acme grupė.
We never disclose any confidential information of Acme grupė when communicating through external
channels, unless otherwise instructed by Acme grupė company in a particular case. Before accepting
an invitation to represent Acme grupė on public channels (this includes invitations from journalists) or
at public events, we firstly contact our immediate supervisor. In case of expressing our own opinion
on the internet or on social media, we communicate unambiguously in order to give a correct
impression that such information is not expressed on behalf of Acme grupė.
Applicable to Third Parties
The Acme grupė expects Third Parties to refrain from any public communication that is disrespectful,
unprofessional, discriminatory, or propagandistic in nature. Third Parties are also expected not to
disseminate information that could create the false impression that they are expressing opinions on
behalf of the Acme grupė, acting in the interests of the Acme grupė, or representing the Acme grupė
without the Acme grupė prior explicit consent.
Third Parties should also avoid any external communication that could disclose confidential
information relating to the Acme grupė business activities, transactions, or other non-public
information.
6. ACME GRUPĖ WORKING ENVIRONMENT
6.1. Responsibility to employees
Applicable to Group Employees
At Acme grupė, we create a motivating work environment in which every employee feels important and respected, and where their human rights are properly protected. We aim to adapt to the changing needs of employees and be an attractive employer in the labour market. We provide our employees with opportunities to develop professionally and improve their skills throughout the course of their careers. It is important to us that managers would properly encourage employees and develop an open and meaningful work culture.
Our organisation properly ensures the requirements of labour law. We remunerate our employees in an appropriate and fair manner, taking into account the performance and the job position of a particular employee, as well as labour market expectations. We value each employee’s contribution to Acme grupė business success, as well as to cooperation and building relationships with our customers and partners.
Applicable to Third Parties
Third Parties must ensure compliance with applicable labour laws and regulations governing
employment relationships, including requirements relating to minimum remuneration and working
time, including overtime.
Third Parties must also ensure the protection of human rights and foster humane and motivating
working conditions for their employees.
6.2. Ensuring equal opportunities
Applicable to Group Employees
Principles of equal opportunities and non-discrimination are an integral part of Acme grupė rules of
conduct. In case of co-worker relations, we are respectful, always committed to helping each other
and appreciate others’ efforts in developing a motivating work environment at Acme grupė. Acme
grupė employees are assessed based on their competence, qualifications and individual achievements.
Our organisation strictly prohibits discrimination or harassment based on a person’s gender, race,
nationality, language, age, origin, social status, sexual orientation, gender identity, disability, health
status, intent to have a child, ethnic origin, membership in a political party or association, religion,
beliefs, opinions or views. Where practicable, Acme grupė aims to adapt working conditions for
employees with disabilities so that everyone has equal opportunities to work.
Applicable to Third Parties
Third Parties must adhere to the principles of equal opportunities and non-discrimination, ensuring
equal working conditions regardless of a person’s sex, race, nationality, language, age, origin, social
status, sexual orientation, gender identity, disability, health condition, intention to have a child, ethnic
origin, membership in a political party or association, religion, faith, beliefs, or views.
The Acme grupė also expects Third Parties to foster an ethical and positive working environment
among colleagues and to maintain a zero-tolerance approach towards disrespectful behaviour.
6.3. Prohibition of harassment and bullying
Applicable to Group Employees
At Acme grupė, we do not tolerate any harassment, bullying or other behaviour which could violate
another person’s dignity or is intended for creating a degrading, offensive or hostile environment. Our
organisation completely prohibits sexual harassment. This also includes any actions, language,
suggestions or hints of vulgar nature.
If you believe that you or any other Acme grupė employee, customer or partner has been harassed,
bullied or experienced other misconduct, we strongly encourage you to report it to your immediate
supervisor or the People & Communications Unit. Acme grupė makes every effort to thoroughly investigate all
reports and takes appropriate actions.
Applicable to Third Parties
Third Parties must ensure a working environment in which vulgar, disrespectful, or hostile behaviour
is not tolerated, including harassment, bullying, or any other conduct that may violate a person’s
dignity or cause humiliation.
The Acme grupė expects Third Parties to maintain a reporting mechanism that enables their
employees to safely report such situations to the responsible persons.
6.4. Safe work environment
Applicable to Group Employees
The Acme grupė is committed to ensuring employee well-being and providing a safe and healthy working environment, while promoting a culture that supports and fosters these principles. Each one of us also has an obligation to act in a manner that does not endanger the safety or health of other coworkers or visitors. For this purpose, we must be familiarised with the instructions for safety at work and participate in the trainings for safety at work organised by Acme grupė. To prevent accidents, employees are prohibited from working under the influence of alcohol, drugs, psychotropic or other psychoactive substances.
The Acme grupė is committed to caring for the well-being of its employees and, in the event of an accident, to ensuring that any resulting harm is appropriately remedied.
If you become aware of circumstances that pose a risk to our safety, health or security at Acme grupė work environment, please notify your immediate supervisor or the People & Communications Unit immediately.
Applicable to Third Parties
In conducting their activities, Third Parties must promote employee well-being and maintain a safe and
healthy working environment for all employees. They must also implement preventive measures
aimed at avoiding workplace accidents and ensuring employee welfare.
For example, Third Parties must ensure that employees do not perform their duties while under the
influence of alcohol, narcotic drugs, psychotropic substances, or other psychoactive substances, and
that workplaces comply with applicable standards and safety requirements.
Where circumstances are identified that may pose a risk to the health or safety of employees, such
deficiencies must be remedied without delay. Third Parties should also encourage employees to report
any risks to their health and safety that arise in the workplace.
7. UPHOLDING THE CODE
7.1. Employee trainings
Applicable to Group Employees
Employees receive training related to this Code of Conduct and participate in training on its application
within the organisation. Such training is provided to all newly hired employees and to existing employees at least once every two years, as all employees are required to familiarise themselves with the Code of Conduct and comply with its provisions.
We expect Acme grupė managers to lead by example and to educate and encourage employees to
adhere to the highest standards of business ethics and conduct. We are committed to fostering a
culture of transparency and responsible business practices and therefore encourage internal
discussions on the application of the Code of Conduct.
Applicable to Third Parties
Third Parties must familiarise themselves with the provisions of this Code of Conduct and promote
compliance with them, including through the adoption of appropriate internal policies and procedures.
Third Parties must also ensure the effective implementation of these provisions in the course of their
activities, including in connection with their business relationships with the Acme grupė.
7.2. Reporting misconduct
Applicable to Group Employees
If you notice or suspect any violations of the Code of Conduct of Acme grupė, we strongly encourage
you to contact your immediate supervisor, the Head of People & Culture Unit or to report the violation
of the Code of Conduct via email compliance@acme.lt. This email address may also be used for asking
questions about the application of the Code of Conduct or for expressing concerns about any
questionable conduct within Acme grupė.
Acme grupė undertakes to ensure that all received reports and queries would be investigated timely,
effectively and competently. We guarantee the confidentiality of the persons submitting the reports
and undertake to take all possible measures to ensure that such persons would not suffer any negative
consequences related their reports.
More information on this topic is provided in the Policy on Reporting of Information regarding
Violations of Acme grupė.
Applicable to Third Parties
Third Parties should encourage their employees to report inappropriate conduct or potential violations
of this Code of Conduct, as well as any applicable internal policies, rules, or principles.
The Acme grupė expects Third Parties, upon becoming aware of inappropriate conduct related to the
Acme grupė or having suspicions of violations of the requirements and principles set out in this Code
of Conduct, to contact the Acme grupė or submit a report of a Code of Conduct violation by email to
compliance@acme.lt.
This email address may also be used to raise questions regarding the application of this Code of
Conduct or to express concerns about any conduct within the Acme grupė that may give rise to
concern.
7.3. Liability for misconduct
Applicable to Group Employees
Acme grupė makes every effort to thoroughly investigate any violation of the Code of Conduct. Such
violation may be considered as a significant breach of employee’s work obligations and thus lead to relevant consequences, for example, a warning regarding breach of work duties or a claim for damages and, in exceptional cases, the termination of an employment contract.
If the violation is indicative of corruption or any other criminal offense, Acme grupė takes immediate
steps and promptly notifies the competent law enforcement or other authorities.
Acme grupė may publish information about violations of the Code of Conduct through the internal
means of communication, to the extent that this does not contradict the laws governing the protection
of personal data.
Applicable to Third Parties
Third Parties must make reasonable efforts to ensure compliance with this Code of Conduct and, where
violations of this Code of Conduct by their employees are identified, take appropriate measures to
remedy such deficiencies or determine the employee’s responsibility.
Furthermore, where a violation exhibits signs of corruption or any other criminal offence, Third Parties
must take immediate action and report the matter to the competent law enforcement authorities or
other responsible authorities.
7.4. Procedure for approval of the Code
Applicable to Group Employees
This Code of Conduct shall be approved by the decision of the Management Board of UAB “Acme
Grupė” and shall enter into force from the date of its approval. The Code of Conduct may be amended
or supplemented also only by the decision of the Management Board of UAB “Acme Grupė”, the
amendments or supplements shall enter into force from the date of their approval.
No later than within 5 working days from the date of adoption of the decision of the Management
Board of UAB “Acme Grupė” to approve, amend or supplement this Code of Conduct, the Code of
Conduct shall be additionally approved by the order of the CEO of each other company belonging to
Acme grupė.
This Code of Conduct shall be directly applicable for UAB “Acme Grupė”, and shall apply for other
companies belonging to Acme grupė once the Code of Conduct is additionally approved by the CEOs
of such relevant Acme grupė companies.
This Code of Conduct shall be revised periodically, but not less than once a year, or in case of significant
events (e.g., changes in legislation) and, if necessary, submitted to the Management Board of
UAB “Acme Grupė” for consideration.