CODE OF BUSINESS ETHICS

We are a big business group, holding an important position in the Baltic States and in the market of the Central Europe
therefore we understand that we are responsible for our actions having effect on our clients, employees, society, our environment.

We seek to develop our activities honestly and transparently, follow high standards of business ethics in all the markets and countries where we
operate. We want that all companies of our group follow these standards.

The directions of our responsible activities are defined by the Code of Business Ethics, where we reveal how we create business relationships and follow
standards of conduct communicating with employees, clients, partners, suppliers, governmental and other authorities and the society.

Whom does the Code apply to?

The Code of Business Ethics is intended for all employees of the company group in all markets, countries and areas where Vilniaus Prekyba or its
companies operate (all companies forming the Vilniaus Prekyba company group are hereinafter referred to as the Company or Companies).

Ensuring compliance with the Code

Taking into account best practices of business leaders, the Company shall ensure information provision channels, by which employees, clients, business
partners, suppliers and other interested persons can inform it about conduct that is in breach of the principles set out in the Code of Business Ethics.