CORRUPTION PREVENTION POLICY

1. PURPOSE AND SCOPE OF APPLICATION OF THE POLICY

1.1. The Corruption Prevention Policy (hereinafter referred to as the Policy ) sets out the procedure for combating corruption in the Group Companies of UAB ME HOLDING NT (hereinafter referred to as the Company ), as well as the totality of the applied preventive measures and actions.

1.2. The aim of the Policy is to identify and eliminate the preconditions for corruption in the Group Companies, to ensure more transparent and efficient operation of the Group Companies and to establish an effective corruption prevention system.

1.3. This Policy shall apply to all Employees of Group Companies.

1.4. The Policy shall not modify or abrogate the Employees' job functions, the terms and conditions of the concluded employment contracts, the Group Companies’ rules of procedure, the rules on the use of confidential information, and other provisions of the Group Companies’ internal procedures and the Labour Code of the Republic of Lithuania in force in the Group Companies.

1.5. For the purposes of this Policy, the following terms shall have the meanings set out below:

1.5.1. Group Company shall mean an entity directly and/or indirectly controlled by the Company, regardless of the nature of the entity's activities or the jurisdiction in which it operates, including the Company.

1.5.2. Group Company Manager shall mean the General Manager of a particular Group Company who makes final decisions on violations of the provisions of this Policy and any other matters referred to in this Policy.

1.5.3. Group Companies' Interests shall mean the interest that the Group Companies operate efficiently, profitably, have a good reputation, are trustworthy, that decisions within the Group Companies are made impartially and fairly, and that decisions made by the Employees in the operation of the Group Companies are in the best interests of the Group Companies and meet the Group Companies’ needs and interests, that the Group Companies’ resources are used wisely, and that the decision-making powers conferred by the Group Companies are not misused.

1.5.4. Employees shall mean the persons employed by Group Companies under employment, royalty, service or other contracts and members of the management and supervisory bodies of Group Companies.

1.5.5. Competent Person shall mean a person who receives and examines reports and information submitted on violations of the provisions of the Policy and proposes solutions to the Group Company Manager, ensures the confidentiality of the person who submitted the information on the violation, and manages the internal channels for the submission of information on violations. The Competent Person shall be appointed in a Group Company by order of the Manager of the Company. The Competent Person may appoint another Employee of the Group Company to investigate a specific violation of the provisions of the Policy in accordance with the provisions of the Description of Procedures for Whistleblowing in the UAB ME HOLDING NT Group of Companies.

1.5.6. Related Persons shall mean spouses, cohabitants, partners of Employees, where the partnership has been registered in accordance with the procedure laid down by law, or where the partnership has not been registered but in fact corresponds to the essence of the concept of a partnership, as well as their parents (adoptive parents), children (adoptive parents), brothers (adoptive brothers), sisters (adoptive sisters), grandparents, grandchildren, and their spouses, cohabitants or partners.

1.5.7. Gift shall mean a gratuitous transfer of one's own property to another person, without compensation. A Gift shall include, inter alia , services rendered, tickets to events, payment of travel expenses, holidays, etc.

1.5.8. Bribe shall mean the offering, giving, permitting to give, requesting for, accepting or receiving financial or other benefits in order to induce improper performance of duties or functions or abuse of a person’s position.

1.5.9. Corruption shall mean the conduct by Employees that is inconsistent with their powers, or with the standards of conduct laid down by law or by the internal rules of companies, for personal or third party gain.

1.5.10. Corruption Offences shall mean bribery, trading in influence, graft, other offences committed in the course of providing services for the benefit of oneself or others: abuse of official position or abuse of power, abuse of official authority, falsification of documents or instruments of measurement, fraud, misappropriation or embezzlement of assets, disclosure of business secrets, misrepresentation of income, profits or assets, money or property laundering, interference in the activities of a civil servant or a person performing public administration functions, or other criminal offences where the commission of such offences is intended or required to induce a bribe or a graft, or to conceal or disguise bribery or corruption.

1.5.11. Cronyism shall mean the patronage of friends and acquaintances using one's position and status.

1.5.12. Nepotism shall mean the patronage of Related Persons through position and status.

1.5.13. Abuse shall mean the use or failure to use the rights, duties and powers conferred on an employee of a Group Company by his/her official position, by law, by the company's internal documents and by other legal acts, contrary to the interests of the Group Companies, and to the principles, substance and content of the Group Company activities.

1.6. Other terms used in the Policy shall be understood as defined in the legislation on corruption prevention requirements.

2. KEY OPERATING PRINCIPLES AND COMMITMENTS

2.1. Group Companies shall not tolerate any form of corruption or the forms of corruption referred to in this Policy and in the legislation and shall take all preventive measures to eliminate the preconditions for corruption.

2.2. All Employees of Group Companies shall comply with the provisions of applicable laws and regulations governing the prevention of corruption.

2.3. Professional conduct and integrity shall be required in all business dealings between Group Companies.

2.4. A person who reports a suspected case of Corruption Offence, cronyism, nepotism or abuse shall never suffer negative consequences as a result thereof.

3. CORRUPTION PREVENTION ACTIONS

3.1. Creation of a Group Company culture based on strong values and high ethical standards, as described in the Group's Code of Business Conduct.

3.2. Implementation of a transparent procurement process in accordance with the Group Companies’ procedures.

3.3. Easily accessible information on how to report suspected or ongoing wrongdoings anonymously.

3.4. Group Companies shall organise related training and seminars in order to educate Employees about corruption, its forms and threats.

4. GIFTS AND REPRESENTATION

4.1. Gifts of any kind shall not be tolerated in Group Companies, except for gifts of a representative nature up to a value of EUR 100.

4.2. In case of doubt as to whether a gift/benefit is acceptable, the Employee shall in all cases inform his/her immediate supervisor and notify the Competent Person in the manner provided for in this Policy. The Group Company Manager in which the Employee referred to in this Clause is employed shall make the final decision as to whether the gift/benefit is acceptable.

4.3. The offer, receipt and provision of a gift of substantial value, as defined by applicable law, or the offer, receipt and provision of an exclusive benefit, may constitute an attempt to bribe and may be reported to the competent authorities.

5. SUPPORT AND CHARITY

5.1. Group Companies shall not make donations to foundations and institutions affiliated with politicians and political parties, nor shall they support campaigns or projects initiated by politicians, especially if it could be construed as political contributions.

5.2. Group Companies may provide support and/or charity in accordance with the legislation governing support and charity.

6. NEPOTISM AND CRONYISM

6.1. Patronage of Related Persons, friends and acquaintances or other related persons shall not be tolerated in Group Companies.

6.2. Group Companies hereby prohibit direct command and control relationships that give rise to favourable decisions between Employees who are related by friendship, kinship or family relationships.

6.3. Recruitment shall be carried out in good faith, according to clear rules, taking into account the interests of the Group Companies, the need and the competence of candidates.

7. ABUSE

7.1. Group Companies shall not tolerate any abuse of office. All assets, resources and finances of the Group Companies shall be used exclusively for corporate purposes and needs, and their use shall be governed by internal procedures.

7.2. Group Companies seek to ensure that Employees do not incur personal expenses at the expense of Group Companies or, in the exercise of their duties, have a personal interest in Group Company transactions.

7.3. All confidential information held by the Group Companies shall be used only for the operation of the Group Companies and Employees shall be prohibited from disclosing it to competitors, suppliers or other interested parties.

7.4. Only persons of good repute must hold senior management positions in Group Companies.

8. PUBLICITY AND ACCOUNTABILITY

8.1. Group Companies shall ensure that their activities and objectives are transparent and clearly stated and that public documents are easily accessible to the public, ensuring full disclosure of information.

8.2. Group Companies shall analyse and investigate information received through any information channels about possible abuses, non-transparent procurement, bribery, conflicts of interest and nepotism/cronyism by their Employees, and take immediate action to counteract any negative consequences.

8.3. The management of the Group Companies shall set standards of transparent behaviour and encourage other Employees to do the same.

9. FINAL PROVISIONS

The Policy shall be approved and amended by resolution of the General Manager of the Company.