Corporate Social Responsibility Policy

We aim to become a driving force in the development of agriculture in the Baltics and a leader in the food industry, as well as a sought-after employer.

We pursue these goals through ethical and transparent business management, respect for people, the environment and society.

The aim of the policy: to determine the general trends and provisions of corporate social responsibility of AB Akola Group and its subsidiaries (hereinafter – the Group) for creating a socially responsible business culture and practice within the Group.

The scope of application: AB Akola Group and its subsidiaries. Exception: Dividend policy and remuneration policy apply only to AB Akola group.

The Corporate Social Responsibility Policy of the Group (hereinafter – CSRP) provides that the employees of the Group shall communicate and coordinate interests with various stakeholders, i.e., customers, employees, business partners, competitors, shareholders, governments, regulatory authorities, and local communities. CSRP is based on the following principles: ensuring the rights, occupational safety, and health of the employees, respect for human rights and privacy, ethical and transparent business activities, responsibility for the protection of the environment, assuring human and animal welfare, anti-corruption and sustainable relations with the partners and society. It consists of the individual policies and codes of behavior.

Violations of any of the Group’s policies or codes can be safely reported by email to [email protected].

Policy on International Sanctions Implementation

Policy on International Sanctions Implementation of AB Akola Group sets out the measures for the implementation of the International Sanctions and the provisions for their implementation by the Company and its subsidiaries.

Full text of the Policy here.

Dividend Policy

Dividend Policy aims to increase of the Company’s value by properly informing the Company’s shareholders and other market participants about future long-term returns on investments in the Company’s capital.

1. General provisions

1.1. AB Akola Group Dividend Policy (hereinafter referred to as the Policy) is approved in the light of the development strategy and objectives of AB Akola Group (hereinafter referred to as the Company) and the corporate group of the Company (hereinafter referred to as the Group) to define principles of awarding and paying dividends of the Company tha must be ensured when submitting proposals by the management bodies of the Company regarding the distribution of dividends of the Company.
1.2. The Policy aims to increase of the Company’s value by properly informing the Company’s shareholders and other market participants about future long-term returns on investments in the Company’s capital.

2. Dividends

2.1. The Board of the Company proposes to allocate no less than 20 (twenty) percent of the Group’s consolidated net profit to dividends.
2.2. Dividends cannot be allocated if the Company has financial difficulties, make significant investments, or has not received approval from creditors.
2.3. The Company’s Board decides on the recommended profit (loss) distribution draft for a financial year and submits feedback and suggestions to the Company’s Supervisory Board and the General Meeting of Shareholders.
2.4. The General Meeting of Shareholders decides on the amount and payment of dividends.

2.5. Dividends determined by the decision of the General Meeting of Shareholders are the Company’s obligation to the shareholders. The shareholder has the right to demand the dividend from the Company as its creditor.
2.6. Those persons who were shareholders of the Company at the end of the Rights Accounting day of the General Meeting of Shareholders that announced the dividends or had the right to dividends on other legal grounds are entitled to receive dividends.
2.7. The Company must pay the allocated dividends no later than one month from the date of adoption of the decision to allocate dividends.
2.8. Payment of dividends in advance is prohibited.
2.9. The Company shall pay dividends in cash through intermediaries – securities account managers.

3. Final Provisions

3.1. The Policy is approved and amended by the decision of the Board of the Company.
3.2. The Policy takes effect from the date of its approval and is valid until its change or cancellation (withdrawal).
3.3. The Company’s Finance Officer is responsible for preparing, amendment and implementing the Policy.
3.4. The Policy is published publicly on the Company’s website.
3.5. The Policy is drafted in Lithuanian and English language. If there are any discrepancies between Lithuanian and English, the text in Lithuanian will prevail.

Anti-Bribery and Anti-Corruption Policy

AB Akola Group and its subsidiaries (hereinafter – the Group) are against bribery and corruption of any form, any manifestations of trading in influence, and conflicts of interest. We strive for open competition and ethical terms and conditions of trade, as well as we comply with the legal systems of the countries where we operate.

The major provisions of the Anti-Bribery and Anti-Corruption Policy (hereinafter – the AAP) of the Group are as follows:

1. The Group shall not tolerate bribery or corruption in any form. Corruption is a misuse of entrusted powers while seeking personal gain. It is described as acts or omissions intended for obtaining (either directly or indirectly) material gain or any other kind of gain personally or for another person for the performance or non-performance of their duties or accepting such a gain, as well as offering, promising or granting (either directly or indirectly) material gain or other personal gains to a person for the performance or non-performance of his or her duties. Bribery is offering, giving, authorizing giving, requesting, accepting, or receiving financial or other benefits intended to encourage the inappropriate performance of relevant functions or misuse of a person’s position. Bribery can take various forms, including but not limited to giving cash or valuable gifts, covering travel and entertainment expenses, providing and/or offering career opportunities, leaking valuable and commercially relevant information, etc.
2. Employees of the Group are prohibited from (either directly or indirectly) offering, giving, authorizing giving, requesting, accepting, or receiving a bribe, including through any third party. It is also prohibited to provide financial instruments to other parties in a way that could be considered as negligent financing of corruption. Necessary and appropriate precautions should be taken to ensure that money paid to third parties, such as agents, partners, sellers, and consultants, is not used for corruption purposes.
3. The AAP applies to all employees of the Group (including any persons engaged under civil agreements, as well as any consultants, intermediaries, and other persons engaged to act on behalf of the Group, irrespective of the form of their relations with the enterprise concerned and the applicable remuneration form).
4. In the performance of their duties, the employees of the Group are prohibited from accepting any gifts that may cause a conflict of interest or that may be considered to be exceeding the normal commercial practice and allowing the presumption that the purpose of such a gift is to find favor with the employees or to influence the decisions made by the employees.
5. The Group prohibits offering and presenting gifts in any form, where such gifts are given in order to secure an unfair advantage or to bias the gift recipient’s decisions in respect of the Group.
6. Employees must avoid circumstances and situations in which their private interests could conflict with the interests of the Group. The Group expects its employees to make appropriate and rational decisions in all cases, without seeking their personal gain.
7. Employees of the Group may accept or give official business gifts (e.g., souvenirs), representation gifts, as well as gifts in accordance with international business protocol or traditions, and show or accept business-related hospitality (e.g., participate in business lunches, official dinners, exhibitions, conferences, etc.), if such gifts or hospitality are appropriate in terms of maintaining business relations, have a clearly stated purpose of maintaining business relations, or are aimed at promoting the services provided by the Group, brand awareness and strengthening the image of the Group.
8. In all cases, when giving or accepting business gifts or other benefits offered, employees must follow the principle of reasonableness and assess whether the purpose of such gifts is to make an unlawful influence or not, and whether such gifts or other benefits offered to employees go beyond the normal practices characteristic to fair business relations or not.
9. Support may not be used as a hidden instrument for bribery and/or trading in influence.
10. Trading in influence is understood as unlawful actions of an employee of the Group where the employee, based on his position, powers granted, family relations and/or connections in the workplace environment or any other likely influence, seeks to influence other employees, other companies, institutions or organizations, so that the said persons make actions or, conversely, omissions (lawfully or unlawfully), while exercising their powers.
11. The requirement of the Group is that all procurements are to be carried out in a transparent manner and in line with the equality, non-discrimination, mutual recognition, proportionality, and impartiality requirements, while rationally using the funds for the purchase of goods, services, or works.
12. In the event of a conflict of interest and/or suspicion that such a conflict may arise, an employee of the Group must inform the line manager or his authorized representative immediately and abstain from participation when discussing any issues and taking decisions related to the conflict of interest in question.
13. Necessary and appropriate precautions shall be taken in cooperation with third parties, such as partners, suppliers, and agents. Specific problematic cases shall be investigated and the necessary precautions and actions shall be taken to eliminate or reduce the risk of bribery and corruption related to third parties.
14. Each employee of the Group is personally responsible for compliance with the AAP provisions.
15. The day-to-day implementation of the AAP is a part of the responsibility of the manager of each company of the Group. The manager of each company is responsible for implementing appropriate actions and internal controls to prevent and disclose any instances of bribery and corruption.
16. Employees of the Group are encouraged to reveal any problems. Any employee of the Group who suspects that infringements of this policy are taking place must notify AB Akola Group. The Group gives a clear and unambiguous guarantee of total confidentiality, data protection, non-disclosure and non-victimization for all those giving relevant notice.
17. Any activity or conduct that may be considered to be an instance of corruption or bribery must be corrected immediately, and such activity shall be subject to disciplinary action.

Violations of the policy can be safely reported by email to [email protected].

Remuneration Policy

This AB Akola Group (hereinafter referred to as the Company) Remuneration Policy (hereinafter referred to as the Remuneration Policy) establishes requirements and guidelines in determining the remuneration of the Managing Director and the Board members of the Company.

The Remuneration Policy shall be reviewed on a regular basis to be consistent with the Company’s long-term strategy.

1. General provisions

1.1. The Company’s remuneration system is aligned with the Company’s strategy, short-term and long-term objectives, as set out below:

1.1.1. The Remuneration Policy reflects the tasks formulated by the Company and the balanced short-term and long-term goals set, as well as the responsibilities undertaken.

1.1.2. The Remuneration Policy seeks fair representation and value creation for all stakeholders – employees, shareholders, partners, consumers.

1.1.3. The Company uses the remuneration system with the object to attract talented employees, motivate and retain them, while implementing the Company’s long-term strategy.

2. Remuneration of the Board

2.1. Members of the Board, who are also employees of the Company, get remuneration according to the signed employment contracts.

2.2. Members of the Board may be remunerated with the payments for their activities (tantiems).

2.3. The Company does not pay any other additional benefits to the Members of the Board for their work as Members of the Board.

2.4. Members of the Board may be granted shares of the Company or remunerated with share options only in accordance with the rules of granting shares of the Company, which are approved by the General Meeting of Shareholders of the Company.

3. Remuneration of the Managing Director

3.1. The remuneration of the General Manager shall be in line with financial results of the Company, market conditions, competence, as well as reflect the requirements and responsibilities that the position entails.

3.2. The remuneration package of the General Manager consists of a fixed and a variable parts; share option programs may also be applied.

3.3. The fixed part is determined and approved by the Board and paid in accordance with the rules applicable in the Company.

3.4. The variable part is paid after closing of the financial year by the decision of the Board, taking into account the approved strategy, financial and non-financial objectives, such as: Company’s financial activity, annual results, budget execution, strategic business development, performance of transactions and projects that contribute to implementation of the Company’s strategy, goals and mission, achievement of relevant financial ratios or specific financial objectives. At the initiative of the Board, the General Manager may be additionally granted an incentive payment to encourage a well-done work or well-performed important project that ensures the implementation of the Company’s strategy. The incentive payment is not guaranteed and/or not binding on the Company.

3.5. The General Manager may be granted shares of the Company or remunerated with the share options only in accordance with the rules of granting shares of the Company, which are approved by the General Meeting of Shareholders of the Company.

3.6. The Company may provide other benefits to the General Manager, which are subject to market conditions and may change from time to time. Additional benefits may include entitlement to the Company’s car, health and medical services, pension schemes, other.

3.7. The allocated annual variable portion of the remuneration shall not be deferred. However it might be recovered within 12 months after allocation, if it transpires that allocation was calculated on the basis of false or misleading information provided by the General Manager. The decision is taken by the Board.

3.8. In the event of termination of employment, voluntarily or on the initiative of the Company, there is no agreed compensation, yet in each case the redundancy pay may not exceed the sum of 24 fixed salaries. Other conditions are determined by the effective legal acts.

4. Final provisions

4.1. The Remuneration Policy enters into force after its approval by the General Meeting of Shareholders of the Company.

4.2. The Remuneration Policy and information on the implementation of the Remuneration Policy are published on the Company’s website.

Violations of the policy can be safely reported by email to [email protected].

Occupational Safety and Health Policy

The business success largely depends on safe and healthy work environment. Thus, the aim of AB Akola Group and its subsidiaries (hereinafter – the Group) is to ensure physical, mental and social health of the employees at their workplaces and productive working environment. Occupational Safety and Health Policy of the Group is designed for creating occupational safety culture based on personal responsibility and cooperation within the companies of the Group:

1. The aim of the Group is to provide safe and healthy working conditions at the workplaces and to improve them regularly. To this end, the Group shall ensure the safety of the work processes, respond to health risks, hazardous and dangerous factors in the working environment, implement preventive measures and promote any measures helping to maintain health and welfare.
2. The approach of the Group to the occupational safety and health of the employees is based on the culture of prevention and dialogue. Prevention first of all means risk management. Accidents, incidents, injuries, occupational diseases, unsafe actions and unsafe conditions can be avoided by analysing work processes and taking proper preventive measures to avoid or reduce the risk. The culture of dialogue means involvement of employees and their constructive participation in ensuring safe and healthy working environment.
3. The Group strives to create a business culture, where every employee understands the importance of compliance with occupational safety and health requirements in their daily activity. It strives to ensure the immediate response to health risks and working environment hazards is an important part of the business activity standard of every company of the Group.
4. Every employee of the Group shall be personally responsible for his health, comply with occupational safety and health rules and cooperate with the management of the company in taking decisions concerning occupational safety and health assurance (employees may point out the issues and suggest possible solutions).
5. The managers of the entities shall show a good example in occupational safety and health assurance. They shall ensure that the employees of the companies have their health checks on a regular basis, promote healthy lifestyle and risk prevention.
6. The Group believes that it is crucial to involve all the employees in efforts to reduce health risks and working environment hazards. Thus, the employees are expected to participate actively in creating safe working environment.
7. The entities of the Group shall prepare and approve internal procedures for creating safe working environment and for responding to health risks and occupational hazards. They shall ensure that the employees are well aware of such procedures and requirements. They shall also ensure that all the employees are qualified for their positions, also that they are properly instructed and trained to apply safe working techniques.
8. The managers of the entities shall implement occupational safety and health procedures required according to the type of activities of the company, provide sufficient resources to ensure safe working conditions, visit workplaces and discuss any occupational safety and health issues of concern with employees.
9. The managers of the entities shall identify any potential risks in their company and be ready for potential emergencies/critical situations and accidents.

Violations of the policy can be safely reported by email to [email protected].

Non-discrimination Policy

AB Akola Group and its subsidiaries (hereinafter – the Group) strive to create working environment, where all the employees could realize their full potential.

The Group is for the diversity of the employees. So it tries to ensure that any applicants for the vacancies of the company are treated fairly and are employed in the company based on their qualification and skills. The Group promotes working environment and culture, where the dignity of every person is highly respected. The Group believes that all employees must be provided with an opportunity to improve their qualification, to access to professional training, retraining, provided with equal benefits regardless of gender, race, nationality, language, origin, social status, faith, beliefs or convictions, age, sexual orientation, disability, ethnic affiliation and religion.

In implementing its principles of gender equality and non-discrimination on any other grounds, the Group establishes this non-discrimination policy (NP) that implements and defines the general provisions of the Group regarding gender equality and non-discrimination issues and lays down the key guidelines for the implementation of the non-discrimination policy.

1. All the companies of the Group shall apply the same criteria and requirements for the selection of employees. Candidates shall be selected and employed only based on the assessment of their competence and personal features required for the position that they applied for. Only persons, whose qualification and experience are relevant for the position, shall be selected and employed.
2. The employees of the Group, who are responsible for the selection of candidates, job interviews and recruitment, shall be well-aware of the selection criteria and the requirement to implement the equal rights policy. Whenever possible, a candidate shall be interviewed by at least two employees of the company.
3. The announcements about the vacancies shall be prepared so that it is clear for the readers that a person of any gender, race, nationality, language, origin, social status, faith, beliefs or convictions, age, sexual orientation, disability, ethnic affiliation or religion can apply for it.
4. In setting the amount of remuneration for specific employees of the Group, responsible employees shall be guided by objective criteria exclusively related to the qualification of the employee, the degree of responsibility, the type of work, the performance results and other objective criteria. The amount of remuneration must not be set based on employee’s gender, race, nationality, language, origin, social status, faith, beliefs or convictions, age, sexual orientation, disability, ethnic affiliation and religion.
5. All the employees of a specific company of the Group, who are doing the same or adequate work, shall be paid the same amount of remuneration regardless of their gender, race, nationality, language, origin, social status, faith, beliefs or convictions, age, sexual orientation, disability, ethnic affiliation or religion. The same work means doing the same activity that is objectively the same or similar to another activity to the extent that both the employees can replace one another without significant increase in costs for the employer. Adequate work means that it objectively does not require lower qualifications and that it is of the same importance to the employer in trying to achieve the goals of the company, as the work it is compared with.
6. In the companies of the Group candidates for promotion shall be selected exclusively based on the criteria related to their personal skills, abilities, the quality of work and personal achievements in professional field.
7. All the companies of the Group shall provide opportunities for the improvement of qualifications, pursuing professional development, retraining, acquiring practical work experience and shall also provide equal benefits.
8. All the companies of the Group shall take steps to prevent bullying, sexual harassment and giving pro-discrimination instructions.
9. The managers of the entities of the Group shall take measures to ensure that the employee is not subject to persecution and is protected from hostile treatment or adverse consequences if he or she files a complaint concerning discrimination or is involved in a case concerning discrimination.
10. The managers of the entities of the Group are responsible for the communication and implementation of this Policy, i.e., they shall ensure that all the employees of the company are familiar with the Non-discrimination Policy of the Group and comply with it. The companies of the Group shall approve procedures for implementation of the Non-discrimination Policy in the company and ensure that their employees are well aware of it.
11. All the employees of the Group are responsible personally for compliance with the NP in their daily activities and shall notify about any potential or actual infringements of the Non-discrimination Policy.

Violations of of the policy can be safely reported by email to [email protected].

Human Rights, Child and Forced Labour Policy

AB Akola Group and its subsidiaries (hereinafter – the Group) are a responsible business organization operating ethically and complying with globally recognized human rights principles. Our goal is to create a positive working environment, where due respect is given to the dignity and rights of every person.

In our activities, we are guided by two key principles: companies must comply with and respect universally recognized human rights and must not contribute to violations of human rights.

We herewith establish the following Human Rights Policy of the Group:

1. No employee shall face a threat of persecution, physical, sexual, racial, mental, verbal, or other abuse.
2. We shall not employ any person, who is younger than the minimum working age valid in any country of operation of our Group and shall under no circumstances employ teenagers under fifteen.
3. We shall not allow or tolerate forced labor in any company of the Group.
4. We recognize the need and encourage our employees to maintain a balance between work and personal life, and we respect other responsibilities of our employees that are not related to their work.
5. Conflict and moral dilemmas may arise in countries where human rights are violated. In such countries, we shall ensure that our activities do not contribute to the violation of human rights.

Violations of of the policy can be safely reported by email to [email protected].

Animal Welfare Policy

AB Akola Group and its subsidiaries (hereinafter – the Group) are one of the major milk suppliers in Lithuania and the largest poultry producers in Lithuania and Latvia. We work in compliance with the principles of justice and transparency, legislation of the European Union, Lithuania and Latvia regulating animal welfare. Recognizing that animals are sentient beings and in attempt to ensure the welfare of the farm animals, the Group establishes the following Animal Welfare Policy:

1. Good handling of animals and ensuring proper animal farming conditions reflect our progress.
2. The dairy farms and poultry farms of the Group are modern and meet the highest European standards. In their activities they are guided by the following principles: the best conditions possible, balanced nutrition, skilled care and prevention of diseases for farm animals.
3. Farm animals raised in the Groups shall be provided with an opportunity for natural development and behave naturally.
4. High standards of hygiene and sanitation shall be complied with in livestock farms and poultry farms, and the improvement of animal welfare shall be a constant process.
5. During reconstruction of farms, much attention is given to the legal acts regulating animal welfare.
6. Only qualified specialists are employed and working in the agricultural companies and poultry farms of the Group, which enables us to ensure the best conditions for animal keeping in the farms.
7. The Group undertakes to assess its performance regularly in order to ensure top level animal welfare and production efficiency.
8. The managers of the entities of the Group that keep animals are responsible for the implementation of this policy. Therefore, they shall duly communicate it to the employees, so that they are well aware of the policy and comply with it.

Violations of the policy can be safely reported by email to [email protected].

Environmental Protection Policy

AB Akola Group and its subsidiaries (hereinafter – the Group) have a significant impact on the environment in the areas they operate. Therefore, they are concerned with the environmental impacts of their activities. The purpose of the Environmental Protection Policy of the Group (hereinafter – EPP) is to define the main environmental guidelines for the implementation of sustainable development business culture and practice in the companies and business environment of the Group. We strive to apply the principles of this policy in all the companies of the Group, also in all the phases of the life cycle of products and services provided to our customers.

Energy consumption, emission of greenhouse gases and waste are the most important environmental concerns. The companies of the Group must look for ways to save energy, use of renewable energy sources, prevent use of hazardous materials, improve waste management, comply with work environment and product quality requirements, monitor data and information about the impacts of the organization on the environment.

The companies of the Group shall be guided by the following principles:

1. The companies shall fully comply with any environmental legislation and legal acts valid in the countries, where they operate.
2. The companies shall assess and gradually reduce the impacts of their economic activities on the environment along the entire product and services supply chain. The companies shall endeavour to reduce the consumption of energy, raw materials and other resources in every way through the implementation of the latest available eco-friendly technical solutions. Thus, they shall: reduce CO₂ emissions by decreasing the amounts pollutants emitted by the vehicles of the companies; reduce the number of business travels by car and by plane by replacing them with modern eco-friendly means of communications, i.e. video and teleconferences, internet, etc.; reduce the amount of paper used in the offices per 1 employee compared with the previous year; maintain the same water and fuel consumption per 1 employee, as the previous year; and maintain the same energy consumption level per 1 employee as the previous year.
3. The companies shall use and promote development of eco-friendly technologies, products and services. They shall apply high quality and environmentally less harmful materials and measures, as well as processes and technologies that do not contribute to environment pollution and do not cause other damage.
4. The companies shall keep record of the indicators to facilitate the measurement of achievement and change that shall be specified in publicly available annual reports of AB Akola Group.
5. The companies shall support preventive measures for the management of environmental impacts in everyday activities and the entire value chain.
6. The companies shall reduce the amount of waste and arrange for the responsible management and sorting of waste: office paper, cardboard packaging, plastic and electronic devices shall be managed as secondary materials.
7. The companies shall immediately notify the customers, partners and other parties about any unusual situation that might cause significant environmental damage and take every step and measure to reduce or prevent it, and to eliminate the consequences, whenever it is impossible to reduce or prevent it.
8. The companies shall always publish information about their environmental activities transparently and reliably.
9. The companies shall ensure that all the employees are familiar with this policy and promote in every way responsible behaviour and involvement in environmental activities at the workplace and outside the company. They shall also promote sorting and disposal of waste and shall inform the employees regularly about sorting opportunities and benefits.

Violations of the policy can be safely reported by email to [email protected]

Code of Business Ethics

AB Akola Group and its subsidiaries (hereinafter – the Group) strive to increase the value of the shares consistently and therefore seek to ensure long-term and successful activity. The Code of Business Ethics is designed to all employees of the Group in all markets, countries and areas where the subsidiaries operate. Companies of the Group have to maintain daily communication concerning a variety of issues with a wide range of interested parties: customers, employees, business partners, competitors, shareholders, governments and regulatory authorities, non-governmental organizations, as well as local communities.

Fair and meaningful relations are important for the development of a good reputation of the Group, therefore, we are open to society, as well as we are public-spirited.

The present Code of Business Ethics is to reveal how we create business relations and what standards of conduct we follow when communicating, as well as when raising animals.

I. Relations with Customers and Consumers

The aim of the Group is to become the driving force of agriculture in the Baltic States and good example for food industry companies.

Together with farmers, we create a thriving and competitive agriculture of the Baltic States. We help farmers to create an efficient and growing agricultural business.

We care about public health, therefore, not only do we maintain high standards for food production and continuously improve the quality of our products (we were the first producer offering chicken without antibiotics in the Baltic States region), but we are also consistently educating chicken consumers.

We offer our services and products fairly and do not use any dishonest or deceptive methods.

We protect the personal data of our customers and ensure their privacy. We apply measures to prevent any unauthorized access to personal data and only disclose them in the cases provided for by law.

II. Relations with Employees

The aim of the Group is to become the most desirable agribusiness employer in the Baltic States. We are confident that employees are the greatest value of the Group and the creative force that drives us forward.

We strive to be an attractive employer for our current and future employees, capable of attracting, helping to develop and maintaining skilled and motivated people in a professional work environment. We respect and treat fairly all of our employees.

We select employees based on their competence, professionalism and values.

We strive to create a working environment where people are respected, regardless of their individual differences, talents or personal qualities, and the work of the employees is evaluated according to their performance and values-based behaviours.

We do not tolerate any age, race, gender, religion, disability, nationality, sexual orientation, marital or familial status or political views-related discrimination, humiliation, harassment, violence or abuse in respect of our employees or other persons we encounter in our activities.

We properly reward employee work and the results achieved, taking into account the responsibilities of the employees and the situation in the labour market.

We part with employees in good faith.

We strive to create a safe and healthy working environment by ensuring the safety of work processes, preventing potential damage and responding to health-damaging conditions, as well as supporting measures to promote health and well-being.

Each company of the Group has relevant safety regulations applicable to its work environment that are established by laws and internal legal acts of the respective company. Each employee must know and follow the safety rules that apply to him / her and the relevant working environment.

We are against the use of child labour or forced labour.

The Group recognizes the right of employees to join trade unions or other representative bodies voluntarily and to negotiate with the employer.

We respect employee privacy. We collect, store and use personal data of our employees in accordance with requirements of legal acts.

We adhere to the principle that the personal activities of the employees of the Group must not contradict the Group’s intention to ensure the lawfulness and continuity of its activities. Our employees have to avoid any contacts and activities that are contrary to the Group’s legitimate interests or raise doubts about employee loyalty.

We adhere to the requirement that any employee of the Group who intends to engage in another employment relation or in another professional activity, or to become a member of management bodies or participate in other active operations beyond the companies of the Group must notify his / her supervisor in this regard, as well as to make sure that such activity will not raise a conflict of interest.

We respect the political views of our employees and do not restrict their personal political or social activities. However, our employees may not make use of the reputation or resources, including working hours, of any of the companies of the Group for their political or social activities or political interests.

The companies of the Group collect and store confidential information about their activities, employees, customers and business partners. It is the duty of each employee to protect such confidential information from disclosure. We encourage our employees to share their knowledge and experience within the confines of confidentiality. Employees may only share any non-public information with those colleagues who need to know that information for work purposes. Such information may only be disclosed to third parties if it is necessary for the performance of activities or mandatory under applicable legal acts, ensuring that the recipients of such information will keep it strictly confidential.

Any business gifts or hospitality services may only be accepted or offered in accordance with requirements of legal acts and usual business practices. Employees can accept and give symbolic inexpensive business gifts that correspond to usual practices aimed to show hospitality and maintain business relations. Giving or accepting money, loans, support, travel or job offers, compensations, or any other valuable reward may not be considered to be the gifts to show hospitality or maintain business relations.

In cases where employees are permitted to use the Group’s assets for personal purposes, employees must ensure that their activities are not in conflict with law, public order and good morals, and do not infringe the business interests of the Group and do not waste the resources of the Group.

Employees of the Group protect the assets and intellectual property rights of their company. Intellectual property encompasses everything that employees create in a company during their working hours using company’s funds or carrying out their job duties. The Group and its companies own rights to everything that employees create while working in the company.

III. Relations with Shareholders

The shares of AB Akola Group are traded on the Nasdaq Vilnius Stock Exchange, therefore, we have to comply with all the regulations applicable to the confidential information that may affect the price of the shares.

The goal of the Group is a long-term increase in the value for shareholders.

We provide our shareholders with information about the financial position of the Group and the companies in a transparent and continuous manner, as well as we inform them of the most significant changes in our operations that may affect the value of the shares they hold.

We inform our shareholders and market participants at the same time and transparently about all major changes that have impact on the company’s assessment.

We ensure that the information submitted to the market is accurate and communicated in accordance with relevant legal acts, stock exchange rules and Corporate Governance Code.

We publish comprehensive, clear and accurate financial reports for the Group, as well as provide explanations for major changes.

Any comments on the Group’s financial achievements and other material events are made solely by the management of AB Akola Group.

We do not use the internal information of the organization in stock trading. The persons having non-public information at their disposal act in accordance with laws and do not trade securities using the above information, do not advise other persons to engage in such trading based on non-public information, and undertake to ensure the confidentiality of such information.

In maintaining our financial or non-financial relations, we only submit data that correspond to reality and provide our knowledge-based information.

IV. Relations with Suppliers, Business Partners and Competitors

We conduct our business in good faith in accordance with all applicable legal acts and high standards of business ethics.

We strive for long-term partnerships and healthy co-operation, and we make every effort to be reliable partners. We strive to build constructive and mutually beneficial connections.

Any business decisions and actions must be based on the principle of maximum benefit for the Group, customers and shareholders. Such decisions may not be taken to fulfil personal objectives or satisfy personal interests.

We expect from our business partners a fair competition in the field of their business.

We select and evaluate our suppliers and subcontractors based on pre-defined criteria such as quality, price, availability, ability to implement, reliability, service and corporate responsibility, including social and environmental protection aspects.

We expect from our suppliers and contractors the compliance with international standards concerning human rights, working conditions, environmental protection and anti-corruption.

We do not offer or accept bribes or other forms of illegal payments in order to acquire or maintain business.

We do not engage in discussions or negotiations on pricing, market shares or other illegal activities with our competitors.

We keep confidential all and any business information entrusted to us by our business partners and use it only to the extent agreed on with our business partners or established by laws.

V. Relations with State Institutions and Government Representatives

In each country, we operate under the laws of that country and communicate with the authorities in an open and transparent manner.

We provide information to all authorities in a timely and appropriate manner in accordance with legal acts.

We strive to maintain good relations with the supervisory authorities of the countries in which we operate. We ensure appropriate conditions for government representatives to inspect the activities of the companies of the Group, as well as fully cooperate during such inspections. Where any non-conformity is found in our activities, we remove it immediately and take measures to prevent the occurrence of such inconsistencies in the future.

VI. Relationship with Society

We aim to foster good neighbourly relations, to be reliable partners, as well as active participants in social life.

We carry out our daily activities in accordance with environmental protection laws, regulations and permits.

We recognize our responsibility for the protection of human health, the environment and natural resources. The Group promotes a healthy lifestyle, rational management and use of resources, and pays a great deal of attention to waste sorting. We aim to reduce waste and CO2 emissions in performance of our activities.

We are not involved in politics. We do not comment on political events and do not make any political statements. However, the Group participates in the dialogue concerning the adoption of regulatory acts that affect our business.

We collaborate with the public in the course of development of our business activities, maintaining the dialogue and taking into consideration relevant comments.

The companies of the Group do not provide direct or indirect support or funding to any political parties.

We follow a long-term sponsorship policy and support the projects that meet our ethical standards, values, and priorities.

Our employees should avoid speaking in public about the activities of the Group or its companies, if such activities are not related to the scope of their direct competencies. It is important to avoid speaking on behalf of the companies of the Group when expressing a personal opinion. This principle also applies to sharing personal opinions in the social space and online.

VII. Ensuring Animal Welfare

The Group is one of the major milk suppliers in Lithuania and the largest poultry producer in Latvia. Good handling of animals and ensuring proper animal farming conditions reflect our culture and progress.

The dairy farms and poultry farms of the Group are guided by the following activity principles: the best possible environment for farm animals, ensured hygiene, balanced nutrition, skilled care, and disease prevention.

Improving animal welfare conditions in dairy farms and poultry farms is an ongoing process.

Compliance and Reporting potential Infringements

The Board of AB Akola Group is responsible for this Code and carries out reviews of its content and compliance checks.

The daily implementation of and compliance with the Code is the duty of the manager of each company.

Each employee must carry out work in accordance with this Code and is encouraged to report any potential infringements of the Code, as well as to provide examples of best practices.

Any actions that do not comply with the provisions of the Code must be corrected immediately and disciplinary action taken.

Employees are encouraged to report any infringements of the Code via e-mail [email protected] or by contacting their line manager.

Regardless of the methods used for such reporting, any benevolently submitted reports on potential infringements of the Code will be investigated promptly, fairly and thoroughly.

Partner Code of Ethics

AB Akola Group is not engaged in any economic activity, but the companies under its control engage in various economic activities: trade and sales of agricultural raw materials, supply of goods and services to the farmers, crop production, dairy farming, poultry farming, food production. In their activities the companies have to communicate with various suppliers of goods and services, subcontractors, consultants, agents, brokers, to cooperate with thousands of farmers involved in crop production.

The aim of this Partner Code of Ethics is to provide guidelines to AB Akola Group and its subsidiaries (hereinafter – the Group) for the kind of partnership they should be looking for. Individual companies of the Group may establish stricter rules for the selection of partners.

Our goal is to be a reliable and long-term partner and we strive for healthy cooperation. Thus, in cases not provided in this Code of ethics, the Group expects fair, ethical and professional behaviour of the partners.

Partner Code of Ethics encompasses the following principles:

1. Work standards
   • The Group expects the Partners not to use child or forced labour, respect their employees and not discriminate them on the grounds of gender, race, nationality, language, origin, social status, faith, beliefs or convictions, age, sexual orientation, disability, ethnic affiliation or religion, as well as pay fair remuneration.
2. Occupational safety and health
   • The Group believes that Partners must create healthy and safe working environment to all the employees.
3. Anti-corruption
   • The employees of the Group must not accept from or give gifts to the customers, offer a fee or services that could be considered a bribe and influence the decision of another company. The Group expects that the Partners will display the same attitude.
4. Transparency in business
   • We believe that our Partners shall promote fair competition in their activities. We are against obscure agreements on prices, market shares, etc.
5. Human rights
   • The Group shall protect and secure human rights and expects its Partners to display the same attitude.
6. Quality assurance
   • All the products of the Partners shall conform to the parameters indicated in the documents and labels, including the origin, composition (ingredients) and set of goods. The services provided by the Partners shall be in line with the terms and conditions stipulated in agreements and other arrangements.
7. Environment protection
   • Partners must save the environment and comply with the laws and regulations valid in the country, where production activities are carried out, products are delivered or services are supplied.
8. Confidential and restricted information
   • Partners shall ensure the confidentiality of information and data provided by the Group.
9. Personal data protection
   • The Group respects personal privacy and collects data about persons only with their consent. So, the Group expects the Partners to protect personal data of its employees and use them responsibly.

Approval and compliance. The companies of the Group shall approve their Supplier / Partner Code of Ethics and construe it as an integral part (annex) of any agreement. In selecting Partners according to various criteria, the companies shall give priority to the Partners, who recognize and comply with the Partner Code of Ethics.

Violations of the code can be safely reported by email to [email protected].

Personal Data Protection Policy

AB Akola Group and its subsidiaries (hereinafter – the Group) respect the privacy of individuals. The purpose of the Personal Data Protection Policy of the Group is to draw the guidelines and to oblige the managers of the companies of the Group to ensure a proper compliance with the provisions of the General Data Protection Regulation (GDPR) of the EU, the Law on Legal Protection of Personal Data (LLPPD) of the Republic of Lithuania, the Labor Code of the Republic of Lithuania, as well as compliance with other legal acts regulating the protection of personal data, and respect for privacy of individuals.

The Group strives to process the personal data of employees and customers safely and appropriately and to ensure their confidentiality in accordance with legal requirements, and therefore takes all necessary technical and organizational measures to protect the personal data of the employees, partners and clients of the Group:

1. The Group collects and stores the data of individuals solely on the legal basis, to the extent that is necessary and for a period that is necessary, i.e., information that is not used to achieve a specific pre-determined objective may not be collected and stored, and personal data are kept for a period that is no longer than necessary for the purposes of the data processing.
2. Personal data are processed accurately and fairly, they may not be outdated or inaccurate and must be kept confidential throughout their processing period, as well as it is prohibited to disclose any information relating to personal data, unless such information is public in accordance with provisions of applicable laws or other legal acts.
3. The Group processes personal data of its customers solely for the purpose to be able to provide a better consultation, to offer best solutions and to perform contracts concluded.
4. The companies of the Group must adopt internal rules of procedure or policies that define for what purposes, to what extent and by whom personal data of employees and customers are collected, stored and safe-kept. Employees of the companies must be informed about the said rules or policies and have access to them on a regular basis.
5. Depending on the nature of activity of each company and the amount of customers’ personal data collected and stored, it is advisable to endorse the customers’ personal data protection management principles and publish them on the company’s website, so that customers could access them. The companies that do not have websites have a possibility to publish their personal data processing principles at www.akolagroup.lt.
6. Customers of the Group must be provided with the opportunity to consent to or to disagree with the use and accumulation of their personal data and to request the deletion or transfer of their personal data, except for the cases where this would interfere with the fulfilment of contractual obligations. Customers must also be provided with the opportunity to consent to or to disagree with the use of their personal data for marketing purposes by the means of signature or electronically.
7. Companies of the Group must appoint persons responsible for the proper application of the GDPR provisions within the companies and the provision of contact information of the persons to be addressed by the employees in matters related to the GDPR. Companies can use external consultants to develop and implement procedures in line with the GDPR.
8. Personal data processed by the Group are provided to third parties (data recipients) only in the cases and according to the procedure established by laws and other legal acts based on the consent of the data subject or in the presence of other legitimate basis for the provision of such data.
9. Since the largest part of personal data is collected and stored electronically, the managers of companies of the Group must ensure that the personal data collected and stored on the servers, computers or other media of the companies are protected against viruses and other attempts to illegally obtain personal data or personal data leakages.

This Policy applies to and is mandatory for all employees of the Group and data processors engaged by the Group.

Personal Data Processing Rules of the Group.

Violations of the Policy can be safely reported by email to [email protected]