Business conduct

The foundation of business conduct at Oro Navigacija is transparent, responsible, and legally compliant operations, based on a zero-tolerance approach to corruption and high standards of professional conduct across the Company.

Business Conduct Principles

Oro Navigacija strives not only for operational efficiency but also for leadership in responsible governance and ethical conduct. Business conduct within the Company is implemented through a consistent system of policies, processes, and control measures, ensuring that decisions are made transparently, responsibly, and in compliance with legal principles.

Employees and partners of the Company follow the Code of Conduct, which establishes key principles of ethics, behavioural standards, and areas of responsibility. This code serves as a guide for day-to-day activities, helping to ensure transparent relationships, the prevention of conflicts of interest, and responsible decision-making.

Business conduct is integrated into the overall sustainability management system and is reinforced by the Sustainability Policy and related documents, such as anti-corruption, partner ethics, gifts management, and equal opportunities policies, ensuring the consistent application of ethical principles across the Company.

Key Areas of Business Conduct

Ensuring business conduct at Oro Navigacija focuses on the following key areas:

• strengthening a corporate culture based on transparency, accountability, and trust;
• preventing corruption and bribery, ensuring zero tolerance for unethical behaviour;
• preventing and managing conflicts of interest;
• ensuring responsible relationships with suppliers and partners by applying principles of partner ethics;
• ensuring transparent use of public funds and resources;
• strengthening whistleblower protection and a culture of reporting violations;
• maintaining open dialogue with stakeholders and involving them in continuous improvement of operations.

How We Ensure Responsible Operations

Business conduct principles in the Company are implemented through an integrated management system that encompasses policies, processes, and oversight mechanisms.

• The Code of Conduct defines the principles of ethical behaviour, promotes transparency and openness, and supports the prevention of conflicts of interest.
• The Sustainability Policy outlines the Company’s overall approach to responsible operations, transparent governance, and the integration of sustainability principles into strategy and daily processes.
• The Environmental Policy establishes commitments to reducing environmental impact, ensuring efficient use of resources, and complying with environmental requirements across all operations.
• The Privacy Policy regulates the protection of personal data, ensuring its responsible processing and compliance with legal requirements.
• The Anti-Corruption Policy sets out the Company’s commitment to zero tolerance for all forms of corruption, including bribery, nepotism, conflicts of interest, and abuse of position.
• The Anti-Corruption Management System (ISO 37001) ensures systematic identification, assessment, and management of corruption risks, integrating preventive measures into daily processes.
• The Code of Conduct for Business Partners defines requirements for partners to adhere to principles of transparency, legality, human rights protection, and fair competition.

Other Oro Navigacija documents that ensure the consistent application of ethical principles across the Company – from internal processes to relationships with partners and other stakeholders – can be found in the Policies section.

Anti-Corruption and Whistleblowing System

AB „Oro navigacija“ continuously strengthens corruption prevention by applying both preventive and response measures. The Company operates an anti-corruption management system that enables the identification of risks, management of their impact, and ensures compliance with legal requirements and international standards.

An important part of this system is the mechanism for reporting violations. The Company provides internal reporting channels, including a “trust line”, which allow employees, partners, and other stakeholders to report potential violations anonymously or openly. The confidentiality of submitted information is ensured, along with its independent assessment and the protection of whistleblowers from any adverse consequences.

More information on corruption prevention and the applied measures can be found under Corruption Prevention.

Business Conduct Objectives

The main business conduct objectives of Oro Navigacija are:

• ensuring zero tolerance for corruption and unethical behaviour;
• strengthening transparency, accountability, and a trust-based organisational culture at Oro Navigacija;
• ensuring effective prevention and management of conflicts of interest;
• developing responsible relationships with partners and suppliers;
• encouraging employees and stakeholders to actively report violations;
• continuously improving the ethics and compliance management system.