UAB “Credo Partners” Code of Business Conduct and Ethics

We present the Code of Business Conduct and Ethics of Credo Partners UAB (“Credo Partners”). This document contains the principles and values that guide our business and our daily work.

The Credo Partners Code of Business Conduct and Ethics (the “Code”) builds on and promotes Credo Partners’ core values and guides how Credo Partners’ employees should work as part of a team, with business partners, clients, competitors and other members of society. The provisions of this Code are binding on all Credo Partners employees. The Code defines rules and standards of conduct relating to interpersonal and business relationships, and the protection of the company’s assets and image.

Objectives of the Code

• Define norms and rules of behaviour.
• To inform and educate Credo Partners employees on business ethics and conduct in a business environment;
• Raise interest in work.
• Developing staff responsibility.
• Maintain a good, motivating and attractive working atmosphere at Credo Partners.
• Ensure a relationship of respect and trust, encouraging Credo Partners to address problems immediately.
• Protecting staff from conflict situations and unethical behaviour by defining cases of intolerable behaviour.

General principles

• The standards of conduct set out in the Code are binding on all Credo Partners employees and set out the principles of conduct when dealing with each other and with Credo Partners’ business partners.
• We take the necessary steps to enable employees to comply with this Code.
• We strive to conduct our business in accordance with the law and accepted standards of business conduct.

Our values and internal rules of conduct

Credo Partners is guided by the following shared values: trust, integrity, professionalism, responsibility, quality, efficiency and respect, which we understand to mean:

Trust	professionalism	quality and efficiency
Smiles build trust Trust builds trust Credo Partners	the way to success – a professional team member We strengthen our skills and are happy to share our experience and competences with each other and with our business partners	we set high standards for quality and we follow the ISO 9001 quality management system we have in placewe consistently and ambitiously pursue our objectives
Integrity	Responsibility	Respect
We act with honesty and integrity among ourselves and with Credo PartnersTransparent relations with each other and with the business community, zero tolerance for corruptionFair competition	we take responsibility for our work and the environment in which we work, and we follow the ISO 14001 environmental management system	we expect mutual respect from each other we do not tolerate harassment, violence, humiliation, bullying or discrimination in any form we abide by the laws and regulations of the Republic of Lithuania we respect and protect human rights

Areas of application

Equality

• We respect human rights and labour law.
• We apply the same fair and equitable rules in the recruitment, training and promotion of our employees and in our relations with our business partners.
• We follow the Credo Partners equal opportunities policy.
• We treat our employees and business partners equally, regardless of race, gender, sexual orientation, religion or political affiliation.
• We base our relationships on mutual trust and respect for each other, regardless of our roles or functions.

Relations

• We respect the dignity and reputation of all individuals and do not accept abusive behaviour towards others.
• We are guided by the principles of social behaviour and good morals and do not accept any bullying (insulting, humiliating, degrading and intimidating others) or any behaviour that is related to, or has the appearance of sexual harassment.
• We follow the Credo Partners policy on preventing psychological violence and harassment in the workplace.
• We are committed to good relations and cooperation, and do not support the spread of rumours and other content that could lead to conflict.
• We politely report unacceptable or inappropriate behaviour to a colleague, and if no change occurs, we inform our manager.

Communication

• We communicate precisely and unambiguously.
• We provide correct, complete, objective, timely and understandable information.
• We protect and do not disclose sensitive or confidential information, including personal data.
• In the responsible exercise of freedom of expression and the right to diversity of opinion, we publicly express our personal opinions, including on the internet and social networks, in a tactful manner that does not damage the business reputation of Credo Partners.

Work safety

• We work in accordance with the principles of safe working practices.
• We provide health and safety information through periodic training tailored to employees’ responsibilities.

Image protection

• We care about the positive image of Credo Partners.
• We know and understand that behaviour that damages Credo Partners’ image can have consequences.This includes our behaviour outside of work and in the workplace.
• The good behaviour of each employee enhances the image and value of Credo Partners. It is therefore important for Credo Partners to set an example for all managers and employees alike.
• We make sure we look neat and professional, appropriate to the task at hand and follow the rules of etiquette.

Asset protection

• We take care of Credo Partners’ assets because they help us achieve our business goals.
• We do not use the assets entrusted to us for personal purposes, except where specifically provided for. This also applies to property entrusted to us by customers or business partners.

These values are also important to us in our business relationships.

Ethical business conduct

• We comply with fair competition and antitrust laws and do not seek to gain an advantage through unfair or abusive means.
• We price our products and services on the basis of a fair assessment of the work and its quality.
• We do not hire our competitors’ employees to obtain legally protected information.
• We do not spread false information about competitors’ products or services.
• We do not accept attempts to enter into contracts or agreements to fix prices, share suppliers or markets with competitors or counterparties.
• We do not tolerate the unauthorised transfer or acquisition of competitive information, or the sharing of confidential or sensitive information with competitors or other entities.
• We invite cooperation from suppliers whose proposals strike a balance between the best price and other important contract criteria.
• We inform our business partners that we adhere to the Principles of Ethical Business Conduct and require our partners to adhere to these principles.
• We intend to make the Principles publicly available on our WEB site no later than 1 November 2023.

Zero tolerance for corruption

We do not tolerate corruption. We understand corruption as the offering and acceptance of improper favours, influence peddling, and undue influence through the patronage of relatives, spouses or friends, because we seek to ensure that our decisions are not influenced by vested interests or the pursuit of personal gain.

We do not accept any form of corrupt behaviour in our business activities, nor in the actions of our employees and business partners, in particular the following behaviour:

• Promising, offering, giving, requesting or accepting any financial or personal benefit for oneself or any third party,
• Exercising influence, seeking or using influence, whether your own or that of others (including public authorities, companies and other entities), for financial or personal gain.

Conflict of interest

We will report any family or personal relationships with employees of a business partner if we work together with that business partner in the course of our duties. Each such relationship is assessed to determine whether it involves a conflict of interest.

The form for reporting/questioning irregularities and unwanted behaviour is at the bottom of the page.

We also commit to:

• maintain impartial business relationships and make decisions based solely on merit,
• not to take on extra work with the company’s customers, suppliers or other business partners, especially competitors,
• refrain from any action that may be perceived in the future as biased and aimed at gaining an unfair advantage,
• promptly report any potential conflict of interest or situation that may interfere with the impartial, honest and proper performance of our duties,
• working for other companies or engaging in other paid activities, only after timely and proper notification to your line manager.

Gratitude gifts/benefits

Only symbolic business gifts that are customary in business practice are given and accepted in business relationships. Any gift or hospitality that could be construed, directly or indirectly, as a reward, influence or patronage is not tolerated. Employees are prohibited from soliciting, directly or indirectly, gifts and/or hospitality from interested parties and business partners.

Charity and support

• We carry out our sponsorship activities in accordance with applicable laws.
• The support/charity provided by the company is aimed at improving the quality of life of individuals, groups or organisations, in accordance with applicable legislation, and is not bound by any other business relationship between the donor and the recipient.

Treatment of persons discharging public functions

We do not provide any unlawful material or immaterial benefit to political parties and their representatives or candidates for political office, whether such benefits are granted or offered directly or through third parties.

We do not financially support any political party.

Prevention of illicit circulation of money

• We are transparent in our dealings – we do not transact with or work with shady parties whose activities are illegal and whose funds may be derived from illegal activities such as terrorism, drug trafficking, human trafficking or tax evasion.

Intellectual property protection

We use ideas, materials, software, information from other persons or entities only with permission.

We use third-party software that we are authorised to use.

Information security

In both our business and personal activities, we take a responsible approach to protecting information, including the protection of personal data. We implement this principle as follows:

• We base our services on the principles of privacy and security;
• we use appropriate security measures to protect against loss of information, and we protect the information provided to us by our customers,
• We use systems to protect against cyber-attacks and information theft,
• inform our employees and business partners about information security, including the protection of personal data,
• we control access to our premises.

Respect for the environment

• We are committed to protecting the environment according to ISO 14001.
• We operate in compliance with legal requirements and accepted standards; we strive to minimise our environmental impact and are constantly looking for new solutions to achieve this goal.
• We continuously improve our environmental management system and invite our employees to get involved in the environmental improvement process.

Process for handling reports/inquiries relating to breaches and/or non-compliance with the Code

Credo Partners has established a process for handling reports and enquiries relating to violations and/or non-compliance with the Code in order to promote compliance with the Code and its implementing rules.

If you wish to clarify any concerns you may have about the Code, if you believe that someone in your business environment (another employee, customer, supplier or other person) is in breach of the law or this Code, or if you suspect that this Code may have been breached, you can provide information through the following communication channels:

• by completing the Reporting/Inquiry Form on Violations and Unwanted Behaviour (Annex 1), which is also available online at Reporting/Inquiry Form on Violations and Unwanted Behaviour;
• fill in the form for reporting/enquiring about infringements and undesirable behaviour on the Credo Partners WEB site no later than from 1 November 2023.

Anyone who reports a breach/query in good faith is protected. Reporting a suspected violation of the Code will not result in any adverse consequences for the employee/business partner. Any report/inquiry may be made anonymously and must describe the anonymous basis. We will review each report/inquiry seriously and honestly and endeavour to deal with it as quickly as possible. If, based on an analysis of the situation, the need is apparent, appropriate corrective action will be taken.

The handling of notifications and consultations in relation to the Code shall be carried out by the Director and the Executive Director of Credo Partners, who shall deal with and handle notifications and enquiries in confidence. The data of the persons involved is processed in accordance with the laws on the protection of personal data of the Republic of Lithuania.Retaliation is not tolerated against persons who in good faith have used the above communication channels to report possible breaches.