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.