Example of Introduction:

Progress, quality, efficiency and safety are the key values of the company. Being reliable and sustainable our company is developing good relationship with its employees, business partners, customers, state regulatory bodies and the publicThe Company relates the success of its activities with trust of interested persons. To achieve its goals the Company has gathered the team of qualified experts who are constantly improving their skills, and for whom ethical conduct with colleagues, clients and partners is fundamental in their daily performance.  


The Code of Conduct example – the example of Code of Behavioural standards and regulations was developed by the Lithuanian Association of Responsible Business (LARB) on the basis of “Interlux” document[107].

The Code of Ethics / Conduct describes the standards which employees of the Company adhere to. Ethical and legal conduct  is the basis for the behavioural standards.

Our Code of Conduct is the commitment of the Company and the document summarising our propagated values and business principles. This is the expression of professionalism which  the employees enshrine in their  activities and which is expected from their partners.  The commitment to follow the Code of Conduct and the rules therein is one of the key conditions for cooperation and labour relations.

The aims of our  Code of Conduct are:

  • To reveal and consolidate the values, business principles and behavioural standards of the Company.
  • To define the fundamental principles for relations with customers, business partners, state , public l and municipal institutions (their representatives), competitors, shareholders and  employees of the Company.  

Each our employee, having received the information about the non-compliance  (violation of) with any rules, obligations or commitments of the Company as well as about any circumstances that would evidence that  there  exists  a real threat for the interests of the Company, its employees, clients, business partners or shareholders, must report that to the head of the Company.

We respect each our client, colleague, business partner, we commit ourselves to behave respectfully and fairly to the extent that he/she  has no doubts over  the reliability of cooperation.    

We pursue the principles of fair business. We act transparently, reliably and fairly  by separating the public and private interests.

We avoid conflicts of interests i.e. situations, where an employee has to choose between the interests of the Company, its customers or private). The direct supervisor (the head of the Company) shall be always informed in the event of conflict. The pursuit  of private financial interests in performance of official functions  at the expense of the Company, its customers, partners or public finances is not tolerated at the Company. 

Environmental Protection

The Company, as a stakeholder of the responsible business, undertakes to actively reduce its environmental impact, including regular measuring and evaluation of the impact on the environment.

We endeavour that all the employees are adequately informed and trained on the issues related to the environmental requirements. Each our employee must make all possible efforts to reduce the amount of waste and any other impact on the environment.

In our activities  we  endeavour to save natural resources, raw materials and energy, choose our products properly and to purchase and use them in a responsible manner, manage waste and reduce its amount responsibly, support and contribute to the national initiatives on environmental protection.

Compliance with Legal Acts

Compliance with the legal acts  is an absolute  requirement applied to the Company and its employees.

Each employee must be thoroughly aware of the legal acts regulating the performance of his/her working functions.  The heads must provide their subordinates with all necessary explanations and advice in the field of application of the legal acts in  performance of their working functions.

The Company is strictly committed to act in compliance with non-discriminatory and fair operational standards , protect environment and ensure safety and health of its employees.

The Company believes that the employees follow all the laws and regulations for healthcare, safety and environment; obtain all necessary permits and perform their works  strictly in compliance with the requirements of appropriate legal acts.

Working relations and personal commitments

The relations between the Company and its employees are based on the long-lasting cooperation, mutual respect, openness and fulfilment of commitments.

The Company creates the working conditions that meet work safety requirements  for each employee, puts all efforts depending on its opportunities  that employees would avoid stress and feel safe with regard to their  professional position  in future.

At work the employees must behave businesslike: to behave correct, polite,  comply with the rules of communication ethics  and behave the way that their actions would not be detrimental to the business reputation of their Company. 

During non-working hours the employees shall also  avoid any such  situations, where their  misbehaviour might not  be associated with the Company and its reputation.

Politeness and helpfulness are the key principles of collegial communication. Demonstration of negative emotions, voice rise up in speaking or acts of violence against other employee (both psychological and physical) shall never be tolerated. Any type of harassment towards other person shall be strictly prohibited. Unethical, malevolent or other adverse behaviour shall not remain unnoticed or unconsidered.    

Loyalty of employees

The loyalty of employees towards the Company shall be expressed through:

  • The perception of the goals and commitments of the Company  by the shareholders and their proper implementation;
  • Fair execution of lawful instructions by the heads, proper performance of duties;
  • Clear limits of acceptable and encouraged  conduct of employees dealing with customers, partners, state, public and local municipal institutions (their representatives) and shareholders of the Company;
  • Protection of interests of  customers, employees, business partners, society and shareholders;
  • Reporting  all the noticed cases  of corruption or other criminal activities.


Each employee has the right to be treated fairly, collegially and respectfully by his heads, subordinates and other employees performing the same or similar duties. The members of our Company shall not tolerate any  kind of discrimination and harassment (on the basis of race, religion, beliefs, ethnic origin, gender, disability, age, marital status, etc.). All the employees of the Company shall act in accordance with the Code of Conduct.

 The Company shall not tolerate  discrimination on political grounds, religion, sexual and private opinions as well as on marital / health situation or condition. . Personal qualities (honesty, decency, etc.) and competence of the employee are the key criteria based on which the Company makes a decision on his/her  employment.

Conflict of interest

Business transactions should  be implemented to comply with interests of the Company in the best possible manner. . Neither natural, nor legal person , in any relationship with  the employee,  may not gain benefits from the Company in the dishonest manner, using his/her connections with the employee or his/her position  held. 

It is necessary to avoid the situations, where  the conflict of interest between the employee’s  liability against  the Company and his/her private interests occurs.   The employee must avoid any circumstances which might cause damage to  the reputation of the Company or other material and immaterial  interests of the Company.

Participation in the activities of other entity, which competes with the Company, in any legal form  (including investment in such entity or having any financial interest from this entity) without a written consent by the Company shall be incompatible with labour relations in  the Company.

All conflict situations related to labour relations within the Company  shall be resolved immediately and firmly. The Company shall  not prohibit its employees to be engaged in the activities which neither has, nor might have a negative impact on  the interests of the Company and proper performance of the working functions of the  employee. Still, the employee must inform about them  in writing prior to the start of such activities in order to avoid the conflict of interests.

Relations with customers, partners, representatives of public institutions

Our relations with customers, partners and representatives of other institutions are based on respect, integrity, professionalism, mutual trust, justice, priority  of customer interests, compliance with commitments, information sharing and the priority of negotiations against legal actions.

The employees of the Company must make every possible effort to prevent any manifestations of corruption.

Relations with competitors

Our relations with competitors shall be based on the principles of honesty  and mutual respect.

In case of any disagreement or conflicts in entering into competitive actions, the negotiation and compromise are always a priority. 

Fair competition is the fundamental  principle in the performance of the Company. Information on the activities of the competitors shall be collected only by lawful and publicly available information collection means. 

Information and Communication with the Public

All the information on its activities the Company shall disclose strictly  in accordance with the requirements of legal acts of the Republic of Lithuania  and  following such principles as: authenticity, regularity, operability, balance between  the private and public interest. 

The employees of the Company must refrain from disclosure of any information to the mass media representatives, except for  such cases, where the appropriate written instruction is obtained from the head of the Company. 

Information on behalf of the Company both to the mass media and any third parties  that are not the customers or partners of the Company shall be provided only by the authorised person or the head of the Company. 

Confidential information related to the activities of the Company  and its partners shall be  kept in strict secret by each employee of the Company. The employees of the Company  declare their participation in political or trade, branch associations, communities and other non-governmental organisations in accordance with the procedure established in the Company.

Bribery, facilitation payments, business lunches and gifts

The Company shall never aim to gain business advantage by unlawful means. It shall be strictly prohibited to offer or give bribes to the third parties in the activities of the Company.  

None of the employees may make  any payments, give bribes, and offer unfair financial benefits to the customers or other persons implementing public functions, thus endeavouring to maintain commercial relations in providing services or obtaining other benefits.  

In performance of  their functions, it shall be strictly prohibited for the employees of the Company  to accept any gifts, and for  the customers, business partners or their representatives to give them as well as to accept money or conclude contracts for privately received reward from the latter. .

The employees of the Company must not grant any hidden privileges to the customers, business partners, representatives of state or municipal, or public institutions.

The repayment with expensive gifts and all other forms of illegal payments, services or other remuneration by the employees to the customers, representatives of state, municipal or public institutions, or other third persons, which are in business relations with the Company,  for the taken or non-taken decisions in favour of the Company is strictly prohibited.

An employee of the Company  who suspects that any third party (customer, colleague, etc.) is trying to involve or use him/her in conclusion of  unlawful transaction, must report that to the head of the Company. In case of doubts, the beneficiary should apply to (the title of an appropriate authorised person) for the advice and instructions.

Business lunches and business gifts to the employees should comply with the general policy for business expenditure  and the rules and requirements of the government institution concerned or those of a legal person.. The third parties shall not be involved in order to circumvent the  attitudes of the aforementioned politicians.

Benefit provocation

The term  “benefit” includes: gifts, loans, tax benefit, reward, position, employment, transaction, services, support, etc.

The Company shall prohibit for both  the heads or employees to provoke  any benefit from the customers, suppliers or any person related to the business of the Company. 

Benefit acceptance

The heads  and employees must refuse to accept a benefit offered on account of their position held, if the acceptance of the benefit might affect their objectivity or force them to act against the interests of the Company, or if that might result in partiality  complaints. 

The heads or employees (by  immediately informing  their head on this case) may consider and voluntarily accept the  benefit  provided only if:

  • The  benefit accepted has no impact on the performance results of the beneficiary;
  • The beneficiary does not feel obliged to repay the giver by doing something for him;
  • The beneficiary may openly discuss the  received benefit without any reservations;
  • The type (for example, promotional or agitation gift, on the occasions of holidays/celebrations) and the value of the benefit received are such that refusal to accept it  is  considered as non-amicable or impolite behaviour.

Gifts should be of low value  and granted not often.

Benefit offer

Any payments, agreed favourable conditions or other advantages provided by the heads or employees in performing the  Company’s activities, shall comply with  the Company’s prevalent practice  in dealing with such issues, and they shall receive the prior written approval of the director. 


Although entertainment is an acceptable form of  business and public conduct, the heads  or employees should refuse  invitations to  catering institutions  or entertainments that are too often in order to avoid discomfort or loss of objectivity in performance of the Company activities.  If the refusal  of invitation is discourtesy, the head or employee may accept the invitation upon agreement that he/she would be allowed to respond the same way.

PROTECTION of interests of the Company,  its shareholders, customers, business partners and employees

The Company makes all the possible efforts to protect and defend the rights and lawful interests of its shareholders, customers, business partners and employees.

The  employees of the Company should take all possible reasonable  actions dependant on their will in order to prevent any unlawful actions of any employee, customer, business partner or any third party, which would cause damage  to the State and the public in general as well as to the Company , its customer, employee or business partner individually.

The employee of the Company must refrain from any action which would  breach good character or  the security of legal  norms. The Company shall preserve the full confidentiality of the persons who reported the non-compliance to the norms of this  Code of Conduct and ensure their  protection  as provided by laws.

 Use of Information Technologies

The Company shall  not tolerate the use and storage of any information humiliating the honour and dignity of the person as well as any other illegal information in the  in IT systems or data storage carriers of the Company.

The Company encourages the employees to use information technologies (computers, IT networks, mobile phones, e-mails and the Internet) responsibly. The employees must not forget that by using information technologies they are responsible for our information security, loss, impairment or damage of technologies.

The computer hardware located in the premises of the Company e may not be used for writing of comments in the Internet (including blogs and social networks) or answering the comments of other persons. 


Where the employees fail to comply with the provisions of the Code of Conduct, the Company may apply disciplinary measures, including dismissal from the office.  Each employee shall receive a copy of this Code of Conduct. The obligation of the management is to ensure that the Code of Conduct is included into the employee training programmes.

The management shall regularly  monitor whether  the Code of Conduct is pursued, and, if necessary, implement specific  monitoring programmes.  The direct supervisor or the appointed   authorised person shall be  addressed with regard to the violations of the Code of Conduct observed. The observed violations of the Code of Conduct shall also be reported by e-mail: etika@bendrovė


The Code of Conduct shall be implemented by all companies of our group. 

We pursue that our suppliers, partners and their supply chain would also implement the provisions of our ethical conduct.


[107] Link to the original document: