CODE OF BUSINESS ETHICS

This Code of Business Ethics (hereinafter referred to as the Code) defines the ethical principles and standards to be followed by the companies of the UAB ME HOLDING NT Group of Companies (hereinafter referred to as the Company, which are collectively referred to hereinafter as the Group.

This Code is the Group's set of basic standards of conduct and ethical principles to which all Group companies and employees adhere in their day-to-day business activities. The Code is intended to disclose and enshrine the Group's core values, operating principles and standards of conduct.

The Code has been drawn up in accordance with applicable legislation, international guidelines and the Group's core values. This Code is the Group's commitment, summarising the Group's values and business principles.

1. TERMS

As used in this Code, the following terms shall have the meanings set out below:

1.1. Employee shall mean a person employed by any Group company under an employment contract.

1.2. Group Company shall mean entities directly and/or indirectly controlled by the Company, which directly and/or indirectly control an entity, irrespective of the nature of the entity's activities or the jurisdiction of its operations.

1.3. Conflict of Interest shall mean a situation in which an Employee, in the performance of his/her duties (or tasks), is required to make a decision (or participate in the making of a decision) which relates to the Employee's private interests.

2. GROUP VALUES

The Group shall be guided by the following core values and expects every employee to follow them:

2.1. Growth. We strive to grow and develop both personally and as an organisation. We look for opportunities to grow and do better than yesterday. As an organisation, we invest in continuous growth and improvement.

2.2. Diligence. To be the fastest and the market leader. We set ourselves ambitious goals and live for the results. We are driven by a desire to lead. We are aware of our own and others' contribution to the overall result.

2.3. Focus. We work for the common results. We consult and find solutions together.

3. TRANSPARENCY

The Group does not tolerate bribery, graft, influence peddling, money laundering, abuse of office (nepotism). There is zero tolerance of corruption and all forms of bribery are prohibited.

Employees of the Group must refrain from any actions or transactions that contravene the anti-corruption and anti-money laundering laws of the Republic of Lithuania and the European Union and other relevant legislation.

The Group shall ensure that its activities and objectives are transparent and clearly stated. The Group encourages the public, suppliers, contractors and employees to get involved in the fight against corruption and encourages them to report any irregularities they see. The Group's management and heads of business units set the standards for transparent behaviour and encourage other Group employees to do the same.

4. MANAGEMENT OF CONFLICTS OF INTEREST

In all business dealings, the Group's employees shall act impartially, shall not provide any undue advantage to other business entities, and shall not create any situation that creates or may create a conflict of interest with the interests of the Group. All decisions must be taken in accordance with the principles of justice and fairness.

Employees of the Group must avoid any situation which may cause the employee's personal interests (pecuniary, non-pecuniary, family or kinship ties or other similar personal interests) to conflict with the interests of the Group. The Group is prohibited from seeking personal gain at the expense of the Group, from using one's employment or position to cover one's personal expenses, and from entering into transactions with persons related by family, kinship or similar ties, suppliers, contractors, etc.

Employees of the Group must also avoid any situation that may give rise to a conflict of interest between the interests of the Group and those of the Group's partners (customers, suppliers, contractors or others).

Any employee of the Group who encounters any conflict of interest in the work environment must immediately report it to the competent entities in accordance with the procedures set out in the Group's Conflicts of Interest Management Policy.

5. FAIR COMPETITION

The Group's relations with the Group's competitors shall be guided by the principles of fairness and respect, and the Group conducts its business ethically, responsibly and transparently. The Group shall avoid circumstances that could violate any principles of fair competition. In the event of any disagreement or controversy over competitive practices, the Group's preference shall always be for negotiation and compromise.

Competition law shall apply to all of the Group's business agreements, regardless of their form or content. Agreements with competitors to coordinate market activities shall not be tolerated by the Group and shall be prohibited.

6. CONFIDENTIAL INFORMATION

Employees shall be required to observe confidentiality obligations and not to disclose to any third party any of the Group's confidential information obtained in the course of their work for the Group. All non-public information which, if disclosed, could be advantageous to competitors or detrimental to the Group, as well as to the Group's customers, suppliers and other business partners, shall be considered as confidential and proprietary information. Confidential or proprietary information may be disclosed to a third party only on a need-to-know basis, unless disclosure is required by law. If an employee is unsure whether information is confidential and proprietary and whether disclosure is permitted, the employee must consult with his/her immediate supervisor or higher management.

Detailed confidentiality obligations shall be set out in internal rules, which must be strictly observed.

7. EMPLOYEE PRIVACY

The Group respects the privacy of its employees. Employees' personal data shall be collected, stored and used in accordance with the provisions of data privacy legislation and the Group's personal data processing rules in force.

8. RESPECTFUL BEHAVIOUR AND ENSURING OF EQUAL RIGHTS

The Group's activities shall be based on and comply with the generally accepted United Nations human rights provisions and labour laws. The Group does not tolerate any form of discrimination or differential treatment in the workplace, including, but not limited to, discrimination on the grounds of age, sex, race, nationality, language, origin, social status, religion, beliefs or opinions, sexual orientation, disability, ethnicity, religion and/or other characteristics protected by law.

In the working environment, humiliation, harassment and violence, whatever their form, shall not be tolerated, nor shall threats of violence or any other form of intimidation, or any other form of intolerable behaviour towards employees as provided for by law. Every employee shall have the right to fair and respectful treatment.

All persons in the Group shall be subject to the same employment opportunities and terms and conditions of employment, taking into account the nature of the employee's activities, experience and competences, and to the same criteria and principles for terminating the employment relationship.

The Group has a single remuneration and bonus policy that sets out the general principles of remuneration management, the structure, review and payment of remuneration and the employee benefits and bonus scheme.

9. OCCUPATIONAL SAFETY AND HEALTH

The Group shall make every effort to ensure a safe working environment, develop and maintain an internal Group culture that encourages employees to appropriately manage the health and safety risks associated with their work activities, and ensure the continuous improvement of the occupational health and safety system.

In the working environment, employees shall be required to comply with fire safety and occupational health and safety requirements, and shall be made aware of, and must comply with, the applicable occupational safety and health instructions. The Group encourages employees to update their knowledge on a regular basis, strives to ensure that every employee in the work environment is also concerned about the health and safety of other employees, and informs supervisors about unsafe working conditions.

In order to ensure the safety of employees, the Group does not tolerate the use, possession, disposal, distribution or production of alcohol or other psychotropic substances in the workplace.

10. ENVIRONMENTAL AND SOCIAL RESPONSIBILITY

The Group understands that its activities are directly related to environmental impacts. The Group complies with all environmental legislation of the Republic of Lithuania and the European Union that is mandatory for the conduct of the Group's activities, and seeks to find the best solutions to minimise the harmful impact on the environment by selecting sustainable and safe solutions.

The Group makes every effort to conserve resources, to find, provide and implement solutions that are as environmentally friendly and environmentally friendly as possible, and to set high standards for environmental protection in the Group's operations. The aim is to ensure that all of the Group's existing and future assets are certified in accordance with internationally recognised certification schemes, and are sustainable and safe for the environment and people.

The Group expects all of the Group's partners (customers, suppliers, contractors, etc.) to be aware of their environmental responsibilities and to adhere to the highest standards in this area and to comply with all the environmental legislation that they are required to comply with.

The Group promotes socially responsible behaviour in all countries and areas of activity, contributing to positive change in societies and communities. Group employees are encouraged to maintain an open and constructive dialogue with institutions, customers, suppliers and other stakeholders involved in the Group's activities.

This Code shall be approved and amended by resolution of the Company's General Manager.