Code of Conduct

1 Introduction
While doing business HARJU ELEKTER UAB has strong commitment to environment, social sustainability and governance (later ESG) development. As a result of this commitment, HARJU ELEKTER UAB has subscribed to the principles of the United Nations Global Compact (www.unglobalcompact.org). HARJU ELEKTER UAB organises all its business to comply with the UN principles in addition to the laws of the Republic of Lithuania.
HARJU ELEKTER UAB strongly believes that it is in the mutual interest of both HARJU ELEKTER UAB and its partners to meet the present and future requirements of markets and society. This includes demonstrating responsibility towards the people taking part in the manufacture and delivery of products and services.
In order to make its position clear to all partners, HARJU ELEKTER UAB has established the HARJU ELEKTER UAB Code of Conduct (the "Code"). The Code describes HARJU ELEKTER UAB corporate ESG responsibility requirements for itself also for partners. As a condition of doing business with HARJU ELEKTER UAB, we expect partners also to comply with these requirements. It is HARJU ELEKTER UAB intention to maintain this Code in a spirit of constructive internal dialogue also equal dialogue with partners, for the mutual benefit of all parties. In the Code, the term "HARJU ELEKTER UAB" refers to HARJU ELEKTER UAB (www.harjuelekter.lt and www.rifas.lt).

2 HARJU ELEKTER UAB Code general requirements
2.1 Area of application
The Code applies to the HARJU ELEKTER UAB and all business partners (the "Partner").
2.2 General Responsibilities
HARJU ELEKTER UAB will take and expects that Partners shall take all necessary actions to ensure compliance with this Code, without undue delay. In addition to complying with the Code, HARJU ELEKTER UAB will comply with applicable local laws. HARJU ELEKTER UAB and Partners are solely responsible for the costs of complying with the Code.
If HARJU ELEKTER UAB finds or suspects incidents of non-compliance with the Code related to Partner and HARJU ELEKTER UAB informs Partner hereof, HARJU ELEKTER UAB expects the Partner to investigate and correct issues of non-compliance as soon as possible and within reasonable timeframe. Also if Partner finds or suspects incidents of non-compliance with the Code related to HARJU ELEKTER UAB and Partner informs HARJU ELEKTER UAB hereof, Partner should expect HARJU ELEKTER UAB to investigate and correct issues of non-compliance as soon as possible and within reasonable timeframe. HARJU ELEKTER UAB promotes equal ethical business practices with all partners and employees. HARJU ELEKTER UAB is expecting all business partners and employees to accept and promote equal ethical business practices.

2.3 Site Audit
HARJU ELEKTER UAB is open for announced audits at HARJU ELEKTER UAB factory and also may conduct announced audits at the Partner's sites, including the Partner's manufacturing facilities in order to verify that the Partner is in compliance with the Code ("CoC audit"). CoC audits may be performed either by HARJU ELEKTER UAB, by Partner’s employees or by third-party auditor.

3 Contact
For general questions or comments on the Code, Partners may contact HARJU ELEKTER UAB at info.lt@harjuelekter.com or +37045582728.

4 Behaviour
4.1 Child Labour
HARJU ELEKTER UAB respects the children's right to development and education and does not employ children under the age of 18. Therefore, HARJU ELEKTER UAB does not accept the use of child labour as a part of the full-time work force at the Partner. This includes employing children under the age of 18, children younger than the legal minimum age, or children younger than age of completing compulsory school.
In general, all children under the age of 18:
• must not be employed in hazardous work*
• must not work night shifts
• are entitled to twice more breaks than adults
* Hazardous work is work which, by its nature or the circumstances, is likely to harm the health, safety or morals of children.
4.2 Discrimination
HARJU ELEKTER UAB respects cultural differences and does not practices discrimination at work based on race, religion, gender, age, nationality or sexual orientation. HARJU ELEKTER UAB employees must not be exposed to any physical punishment, threats of violence or physical, sexual, psychological or verbal harassment or maltreatment in the work place or in work related situations.
4.3 Forced Labour
The Code does not permit forced or involuntary labour at HARJU ELEKTER UAB. This includes forced prison work, work on a forced contract, slavery and other forms of work, which are done against one's will or choice.
HARJU ELEKTER UAB does not tolerate employment which confines the employee in unreasonable debt bondage.
4.4 Working Environment
HARJU ELEKTER UAB supports the fundamental human right to have sound working conditions. HARJU ELEKTER UAB ensure a good and safe working environment which complies with all applicable rules and laws. As a minimum:
• Workers must not be exposed to dangerous work without being properly protected. Workers must be provided personal protection equipment and be instructed in its proper use.
• Facilities must comply with applicable laws and rules about construction safety as well as fire protection — and fire alarms.
• Facilities must provide appropriate light and ventilation.
• All dangerous materials must be stored in safe places and used in safe and controlled ways.
• All machinery must be properly maintained and shielded.
• Facilities for meals, resting and sleeping, must, if provided, be kept clean and safe.
4.5 Working Hours and Salary
HARJU ELEKTER UAB recognises the need for a sound balance between working time and leisure time for all employees.
Unless the law provides otherwise, the maximum working time at the HARJU ELEKTER UAB sites is 40 hours per week plus maximum legally allowed overtime work. All workers shall be allowed to have at least one day off in a period of seven days unless the national law/rules provide otherwise.
Salaries for work and overtime shall be in accordance with the applicable national law or applicable national rules. Deductions in salary due to company fines or penalties must never compromise minimum salary.
4.6 The Right to Organise and Collective Bargaining
HARJU ELEKTER UAB do not interfere with the worker's right to form and join unions or to bargain collectively. This means that HARJU ELEKTER UAB do recognise its employees' right to choose whether or not to associate with or establish any organisation including labour organisations. If trade unions are not allowed in the area of operation, or only state authorised organisations are allowed, HARJU ELEKTER UAB always facilitate alternative measures to allow employees to access management to discuss work related matters.
4.7 Right to privacy
HARJU ELEKTER UAB always respect its employees' right to privacy when it gathers or keeps personal information or implements employee-monitoring practices.
4.8 Environment
Environmental considerations are an integral part of HARJU ELEKTER UAB business practices. HARJU ELEKTER UAB commit to reduce the environmental impact of its manufacturing process.
• Pollution Prevention and Resource Reduction. HARJU ELEKTER UAB will avoid pollution and actively strive to reduce material consumption.
• Chemicals and Hazardous Materials. HARJU ELEKTER UAB will ensure that chemicals and hazardous materials are handled, stored and disposed in an environmentally safe way,
• Air Emissions. HARJU ELEKTER UAB will ensure that air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterised, monitored, controlled and treated as required by law prior to discharge.
• Wastewater and Solid Waste. HARJU ELEKTER UAB will ensure that wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required by law prior to discharge or disposal.
• Recycling and Reuse of Materials and Products. HARJU ELEKTER UAB will contribute to the recycling and reuse of materials and products to the extent possible. The unsorted waste ends up in landfills, where it releases harmful gases and chemical compounds that harm nature, wildlife, and human health. Sorted waste contributes to maintaining a clean environment, conserving ever-scarcer natural resources and energy, limiting deforestation, water, and air pollution. For these reasons, it is important to sort packaging waste separately: paper, plastic, wood packaging waste must be separated from the general municipal waste stream so that it does not end up in landfills but is recycled to alternative raw materials or used for energy recovery.
4.9 Corruption
Corruption and bribery are recognised as barriers to sustainable development and free trade. HARJU ELEKTER UAB does not accept these practices and therefore does not offer or accept any kind of undue payment in any of its business transactions. All received gifts must be collected by Human Resource department and distributed to random workers by lottery within fiscal year.

5 Signature
We, HARJU ELEKTER UAB team, acknowledge that we have read and understand this HARJU ELEKTER UAB Code of Conduct and agree to comply with the requirements of the Code.