Code of Ethics

The Code of Ethics is designed to establish uniform general behavioral guidelines for communication and cooperation both within and outside LINEV Systems EU UAB.

The provisions of the Code of Ethics are based not only on the employer’s obligation but also on each employee’s personal understanding that proper behavior enhances the Company’s business reputation and value while reducing the risk of reputational damage.

Leaders lead by example – This means that each of the Companys managers adheres to the principles of leadership by setting an example by their actions.

We act honestly and thoughtfully – This means that in our professional and personal activities, we comply with the requirements of laws and regulations, when they do not establish appropriate rules of conduct, we behave ir such a way that our conduct complies with the highest standarts of reliability, conscientiousness and transparency accepted in society.

We communicate clearly and understandby – This means that we adhere to the principles of fairness, non-discrimination and equality when we communicate. The information providad is true, complete and in line with the facts.

We act respectfully and understandably – This means that seek equal opportunities for work, career and qualification development regardless of ethnic origin, gender, sexual orientation, marital or social status, paternity or maternity, religion, disability, age. We respect the private lives, views, beliefs, psychological safety and physical integrity of others.

We avoid conflicts of interest – This means that our actions and decisions are based on the principle of loyalty to the Company. We avoid conflicts of interest that could affect an impartial decision or work.

We respect personal data and protect confidential information – This means that we responsibly handle entrusted personal data, disclose only the information that we are required to disclose according to our job function or the requirements of legal acts and policies in force in the company, and ensure that confidential information or information constituting the Company’s trade secret, including entrusted personal data, is protected.

We adhere to corruption prevention – This means that we do not directly or indirectly offer, give, or allow bribes to be given, nor do we request or accept them, so that our decisions are not influenced by personal interests or the pursuit of personal gain.

Reporting inappropriate behavior – This means that we encourage employees and other stakeholders to report potential violations, unethical or unfair behavior directly or anonymously to the anti-corruption compliance officer by phone or email, without fear of negative consequences. The Company takes all measures to protect the person who reports violations or improper behavior within the Company from negative consequences.

korupcija@duomenuperkelimui.eu +370 652 93563

Leaders Set the Example

Every employee’s proper conduct enhances the Company’s business reputation and value. Therefore, it is crucial that managers at all levels serve as role models for their colleagues. This means that every Company leader adheres to the following leadership principles:

Principle	Leadership Behavior
• Sets the direction for change and acts as an ambassador	• Establishes clear goals and ensures feedback. Personally commits to the Company’s objectives. Encourages initiative, diversity of opinions, and continuous progress.
• Unites teams and develops personalities	• Inspires and unites teams. Recognizes team members’ achievements without taking credit for others’ success. Acts transparently and honestly.
• Fulfills commitments	• Adheres to agreed decisions. Recognizes team achievements and avoids self-serving motives.

Principles and Leadership Behavior

We Act with Integrity and Thoughtfulness

In both professional and personal activities, we comply with legal and regulatory requirements. When the Code or laws do not specify behavior standards, we act in a manner that aligns with the highest standards of reliability, integrity, and transparency. Before making or executing a decision, we ask ourselves:

Is my action legal, fair, and ethical?…
Does my behavior align with the Company’s values?
Does my action create value for stakeholders and ensure protection and security?
Would my actions enhance the Company’s reputation if publicly discussed?
Am I willing to ask and report concerns about improper actions?

Employees must ensure a positive Company image through their actions, avoid conflicts of interest, and adhere to etiquette, language, and professional ethics. Employees must maintain appropriate professional appearance and comply with workplace health and safety regulations. Interactions among employees are based on mutual understanding, tolerance, goodwill, and respect.

We Communicate Clearly and Transparently

We adhere to principles of honesty, non-discrimination, and equality in communication. Information must be accurate, complete, and fact-based. We resolve conflicts through collaboration while ensuring accountability. This means that:

We communicate clearly and unambiguously….
We provide accurate and timely information.
We share information on a “need-to-know” basis.
We protect and do not disclose confidential or personal data.
We publicly speak on behalf of the Company only within our designated authority.
We responsibly express personal opinions online and in social media to avoid damaging the Company’s reputation.
We treat the Company’s brand with respect.

We Act Respectfully and Politely

We ensure equal employment, career, and training opportunities regardless of ethnicity, gender, sexual orientation, marital status, social status, parenthood, religion, disability, or age. We respect others’ privacy, beliefs, psychological safety, and physical integrity. Disrespectful behavior, inappropriate remarks, or actions that disturb colleagues are unacceptable. This means that:

We evaluate colleagues based on their work performance.
We treat colleagues with politeness, respect, and dignity….
We do not use or tolerate physical or psychological violence, rudeness, or insults.
We do not engage in or tolerate threats, harassment, or exploitation.
We address inappropriate behavior with colleagues and inform management if it continues.

We Manage Interests and Avoid Conflicts of Interest

Our actions and decisions are based on loyalty to the Company. We avoid conflicts of interest that could influence impartial decision-making. We do not tolerate nepotism in hiring or promotions. We ensure transparency in conflict resolution and interest management. This means that:

We avoid situations that could compromise our loyalty to the Company.
We immediately report any potential conflicts of interest to our direct supervisor.
We abstain from decisions that could grant undue benefits to ourselves or close associates.
We do not use our positions for personal gain.
We disclose any secondary employment or business activities to our supervisor….
We use work time, resources, and materials solely for professional duties.

We Respect Personal Data and Protect Confidential Information

We handle entrusted personal data responsibly and disclose only necessary information as required by legal and internal policies. We ensure that confidential or commercially sensitive information, including personal data, is securely protected. This means that we:

Use workplace information only for professional purposes.
Disclose information only to the necessary extent.
Follow the Company’s information security policies.

We Follow Anti-Corruption Policies

We do not offer, give, request, or accept bribes. Corruption includes offering and accepting undue privileges, influence peddling, and favoritism. We accept only customary symbolic business gifts. Any request for or offer of a bribe must be reported to management. Before accepting a gift or invitation, we ask ourselves:

Is something expected in return?
Is the offer related to my role?…
Are negotiations ongoing with the offering party?
Is the offering party involved in procurement or sales procedures?
Will representatives from other companies be present at the event?
Has my supervisor approved the invitation?
Could I justify my acceptance publicly?

We Report Misconduct

We encourage employees and stakeholders to report violations or unethical behavior without fear of repercussions. Reports can be made directly or anonymously to the anti-corruption compliance officer via the trust line (+370 652 93563) or email (korupcija@duomenuperkelimui.eu). Reports will be investigated promptly, fairly, and thoroughly. The Company takes measures to protect whistleblowers from negative consequences. We understand that behavior harming the Company’s reputation may have consequences for us. Therefore, we always follow the principle of reasonableness:

We ensure our decisions and actions comply with legal and Code requirements.
We take adequate time for complex decisions….
We consult with our direct supervisor in case of doubt.