BALTIC LOGISTIC SOLUTIONS OÜ
ORGANIZATIONAL AND SUPPLIER CODE OF CONDUCT
Annex 5

Baltic Logistic Solutions OÜ, as one of the largest logistics companies in the Baltic States,
is deeply committed to providing the clients with high-quality goods in compliance with
the proper workplace and work conditions that meet the client requirements and
international standards. The company aims to develop a transparent, professional, fair
and ethical business practice and complies with all applicable laws and legislation in all
jurisdictions of the company’s business. We hope that our employees, engaged in their
daily tasks, our partners and suppliers are socially-responsible, respect the human rights,
environmental goals and comply with labour laws and other applicable standards, and
thus we have adopted this Baltic Logistic Solutions OÜ Code of Conduct (hereinafter – the
Code).
The purpose of this code is to establish the major behavioural standards, followed by
Baltic Logistic Solutions OÜ, its entities, partners and employees, compliance to which
ensures the implementation of the highest standards of business ethics in the supply
chain.
This Code is based on the international law, i. e. United Nations’ (hereinafter – UN) Universal
Declaration of Human Rights, conventions of the International Labour Organisation
(hereinafter – the ILO), Guidelines for Multinational Enterprises of the Organization for
Economic Co-operation and Development, the UN Guiding Principles on Business and
Human Rights, the Principles of the UN Global Compact, the Children’s Rights and Business
Principles, corruption prevention and other legislation. This Code is universally applicable
to the business of Baltic Logistic Solutions OÜ and the legal entities under its control, all of
their employees, representatives, intermediaries, and all companies that supply goods
and/or services to Baltic Logistic Solutions OÜ, regardless of the size, geographic location
or industrial sector of the supplier company (hereinafter – the Supplier).

Baltic Logistic Solutions OÜ constantly monitors the application of the provisions of the
Code, regularly conducting trainings and discussions on the topics of the application of
the Code with the employees in order not only to ensure its full application in practice, but
also to achieve higher sustainability and transparency standards.
Baltic Logistic Solutions OÜ adheres to the highest business integrity standards and will
not tolerate any practices that do not comply with the principles of integrity, fairness and
transparency, thus expecting that all Suppliers have already applied the standards,
indicated below.
Baltic Logistic Solutions OÜ remains the right to conduct regular inspections
of any of the Suppliers or their subcontractors to make sure that they adhere
to the requirements, established in this Code, and, should they refuse to allow
such an audit or in case of any violations and refusal to eliminate them, terminate
any cooperative relationship.

Child labour
Children under the age limit, established by the national legislation, will not be employed
and their employment will not be encouraged. Employers that legally employ workers
above the statutory minimum working age, but under the age of 18 must guarantee
proper conditions to ensure their health, safety and well-being. These employees,
employed under applicable legislation, must be protected from participation or work,
which, by its nature or circumstances, could be detrimental to their safety, health and
morale. Employees under 18 years old cannot be appointed for night shifts also hard
and/or dangerous work.

Forced labour
Prisoner or forced labour, as it is defined in the ILO Convention No. 29, will not be used or
encouraged. Measures to secure labour, such as paying security deposit, retention of
employees’ original documents, or refusal to pay salary or other payments, will not be
used. All employees are employed at their own will and can finish their work at the agreed
daily working hours with no application of penalties or salary reduction, and can resign
from their position upon notice, as established in the law, and work overtime only upon
free agreement between the employee and the employer.

Staff safety and health
The company must ensure a safe and healthy environment for all employees, taking all
necessary measures to prevent potential accidents at work and compliance to all
legislation, related to staff safety and health requirements. The company and all
workplaces must undergo risk assessment to reduce them and improve the quality of the
working conditions. The company must establish and implement procedures on
documenting, analysing and preventing accidents based on the applicable legislation.
Before starting to work, all employees undergo trainings and are introduced to work
safety, fire safety requirements, instructions of using machinery and equipment, and all
instructions must be documented. Machinery and equipment, used at work, must be safe
to use, comply with all quality and safety requirements, be certified and, if required by the
law, regularly inspected for compliance to these requirements. Employees are provided
with appropriate work equipment and personal safety measures. They must be provided
with good working conditions that are as comfortable as possible (proper temperature,
lighting, noise control, etc.), have free access to first aid kits and fire extinguishing
equipment in clearly marked places, and, in case of emergency, they must know how to
provide first aid or take other safety measures. The company must implement a
procedure, enabling to prevent work under the influence of alcohol or other psychotropic
substances that interfere with safe and efficient work.

Employees’ involvement in the organisation
The company undertakes to ensure freedom to all employees to establish,
organise and join trade unions or other organisations of their own choice, also enter
into collective agreements with the employer. These rights of the employees will be
respected, not subject to any restrictions, while the establishment, operation or
administration of such employee organizations will not be hindered. The company must
ensure that employees participating at trade unions or other organisations are not
subject to discrimination, harassment, threats or other negative outcomes, or that they
are not subject to any privileges or other special treatment. The Supplier must ensure that
all employees can report their grievances at work with no negative consequences.

Discrimination
Discrimination in terms of employment, salary, training, promotion, termination of
employment or retirement and in other areas in terms of race, national, ethnic or social
origin, marital status, religion, disability, illness, gender, sexual orientation, membership at
unions, political views, age or any other conditions that could give rise to discrimination,
will not be practised or encouraged.

Respectful treatment
All employees will be treated respectfully and with dignity. Corporal punishment,
psychological or physical violence, insults or bullying, any forms of physical, sexual, verbal
or psychological harassment, humiliation or mobbing will not be used or tolerated. Any
threatening, insulting, exploitative behaviour, sexual violence, including gestures, verbal of
physical contact at work and/or other premises of the company or beyond is forbidden.
Employees that violate the company’s work procedure will be immediately subject to
measures, established only in lawful provisions of disciplinary practice. No fines or
deductions from salary are allowed, except to the extent allowed by the national
legislation.

Working hours
The company will adhere to the legislation regarding working hours, holidays, also
entitlement to and payment for non-working days and vacation. A standard working week
cannot exceed the requirements, established in the national legislation. Overtime must
be voluntary and coordinated by mutual agreement between the employer and the
employee. Employees’ work and resting time regime must comply with the requirements,
established in the national legislation, and it cannot compromise the work-life balance of
the employee.

Work payment
The company respects the employees’ right to a fair remuneration for their work and
guarantees that the remuneration for a standard working week will not be lower than the
minimum wages, established by the law, and will be sufficient to meet the employees’
basic needs, considering the average standard of living in the country. Overtime must be
paid at the increased rate, established by the national legislation. There can
be no consistent pattern of short-term employment agreements, or fictitious
training programmes, used for the purpose of attempting to evade obligations to
the employee, related to the labour law and social security regulations.

Business ethics
The economic commercial activity is conducted according to the highest standards of
ethical behaviour and all applicable legislation, including, but not limited to: all necessary
permissions and licenses, adherence to all applicable corruption prevention, fair
competition legislation, fair financial accounting, and all applicable taxes are calculated,
declared and paid to the state. All documents, records and reports must be correct, clear
and reliable. Reasonably and lawfully requested information about the business must be
provided objectively, honestly, without concealing or falsification of facts. The company’s
employees are introduced to the rules of business ethics and apply them at their daily
activities.

Environmental protection
The company complies to the international and national environmental laws, rules and
standards, applicable to its business, and takes responsibility for its impact on the
environment. The company complies with any requirements, related to air pollution,
ground pollution and waste water management. Any type of pollution must be
immediately eliminated and reported to appropriate institutions. Waste water must be
managed according to applicable legislation, and the waste water management
facilities must be properly operated, maintained and renewed. The company must
conduct constant monitoring of the environmental impact on the current business and
operations, periodical reviews of the environmental impact mitigation plans, and take
action to fulfil the goals of mitigating the environmental impact. The company has a
properly implemented waste management, disposal and recycling policy, adheres to
applicable legislation and pays established waste-related fees. The company ensures
proper waste sorting, recycling and disposal, based on their type, including hazardous
waste.

Fair competition
The company is well-aware of its dominating position in the market, if any, and also aware
of the impact any of its decisions may have on the clients, competitors or service
providers. Any company agreements, association decisions or coordinated action with
the aim to prevent, limit or distort competition will not be tolerated. Any agreements of
this kind are forbidden even if their resulting in such outcome is accidental. The company
does not engage in any practice or activity, which violates any legislation on competition
or monopoly prevention, or could give rise to such violations. The company takes no
action or enter into any agreements, which would hinder or harm customers, competitors
or service providers, or which could be regarded as contradictory to legislation on
competition.

Corruption prevention
The company adheres to corruption prevention legislation and rules, and will
not tolerate any non-transparent relations between the company or its partners
and other business or governmental institutions. Any offer, encouragement, promise,
agreement or acceptance of any bribe or other types of illegal payments, including
concessions, any types of gifts or other financial and/or non-financial benefits, also direct
or indirect promise, agreement, payment or offer of any other types of valuable reward
or other benefit, are prohibited. The company and its employees cannot offer or accept
gifts, money, travels or hospitality, which is used as encouragement to make a certain
decision or a reward. The company does not support any political parties or candidates
to governmental institutions, does not engage in any political activities during work and
does not use the company’s funds, premises or other resources for this purpose. The
company’s leadership will fully disclose any information on any support to political parties
or governmental institutions, or any other possible cases of a conflict of interest. The
company adheres to the duty of reporting any information, which may be related to
criminal activity, or other possible cases of corruption to law enforcement authorities. The
company constantly monitors compliance with anti-corruption provisions and organises
appropriate staff trainings.

Money laundering prevention
All financial operations will be transparent and ethical, with adherence to the standard
processes, and the company will not take part at any transactions, which involve
unrelated parties and (or) unusual payment methods, and (or) unusual terms and
conditions. Before entering into any transaction, the company will carefully check the third
parties and apply highest transparency requirements to any related parties of the
transaction. Any suspicious transactions and financial activity is always reported to the
company’s leadership and responsible law enforcement institutions.

Reporting and communication
Adherence to the Code is strictly monitored. The company encourages immediate
reporting of existing and / or suspected violations of applicable laws, regulations, internal
procedures and the Code. Employees can report suspected or existing violations to their
direct managers or use the company’s whistleblower channels. In any case, the company
guarantees anonymity of the whistleblowers and persecution, dismissal or any other
forms of punishment for employees or Suppliers that have reported suspected violations
in good faith, is forbidden.
With no limitations to this Code, Baltic Logistic Solutions OÜ continues to improve its
practice, which complies with highest standards of business ethics, and strives to ensure
compliance with the provisions of the Code in cooperation with its suppliers and
subcontractors. Baltic Logistic Solutions OÜ expects the same from the Suppliers, hoping
for open communication and cooperation any compliance issues and the application of
the Code.