Whistleblowing

MAXIMA GRUPĖ, UAB is committed to conducting its business in accordance with the highest ethical standards and all applicable legal requirements. Therefore, if you have information about a planned, ongoing, or completed legal violation within the Company, we encourage you to report it through the internal reporting channel, the Trust Line.

Contact details of Trust Line:

Reports may be submitted through the Trust Line by completing and submitting to the Competent person the Notification form or in any other written form, indicating that the report is submitted in accordance with the Law on the Protection of Whistleblowers of the Republic of Lithuania, using the following contact details:

If your report concerns one of the companies within the MAXIMA Group, we encourage you to first use the reporting channel of the relevant company:

MAXIMA LT, UAB

MAXIMA Latvija, SIA

MAXIMA EESTI, OÜ

UAB „Barbora“

MAXIMA International Sourcing, UAB

FRANMAX, UAB

If, after assessing the information received, it becomes apparent that the alleged violation relates to a specific MAXIMA Group company and could be investigated more effectively there, we reserve the right, subject to your consent and after ensuring that this would not expose to you any risk, to transfer the report for further investigation to the responsible person of that company.

Reports may be submitted concerning:

Information about planned, ongoing, or completed legal violations, or attempts to conceal them, where such information was obtained through employment, contractual (including pre-contractual), or other legal relationships with the Company. Reports should relate to violations affecting the public interest, including, for example:

• corruption-related violations (e.g. violations of the Company's Corruption prevention policy);
• threats to public safety, health, or human life (e.g. unsafe working conditions or retail premises);
• environmental risks or damage;
• obstruction of law enforcement activities (e.g. unlawful influence or concealment of evidence);
• illegal financing of activities;
• unlawful or non-transparent use of public funds or assets;
• acquisition of assets by illegal means (e.g. money laundering or fraud);
• attempts to conceal violations and/or their consequences (e.g. falsification of data or provision of misleading information);
• violations of competition law (e.g. cartel arrangements or unfair trading practices);
• violations of international sanctions or restrictive measures;
• other violations affecting the public interest.

Reports submitted solely to protect personal rights and/or legitimate interests (for example, violations of employee rights, inappropriate behavior at work, violations of human rights, personal data breaches, etc.) are not subject to the provisions of the Law on the Protection of Whistleblowers, including the statutory procedural deadlines and whistleblower protection measures. However, such reports may still be reviewed in accordance with the Company's internal procedures.

Investigation of the reports:

Your report will be investigated in accordance with the Law on the Protection of Whistleblowers of the Republic of Lithuania. We will:

• no later than within 2 working days conduct a preliminary assessment of your report and acknowledge receipt;
• no later than within 10 working days from the receipt inform you about the decision taken regarding the handling procedure of the report (decision to investigate the report, terminate the investigation procedure, or decision to examine the report in accordance with another procedure established by the Company, if the provisions of the Law on the Protection of Whistleblowers do not apply to the report);
• investigate the circumstances described in the report within 30 calendar days (this period may be extended where objectively justified) and, within 2 working days after the completion of the investigation, inform you of the findings, results of the investigation, measures taken or planned, and any liability imposed on the persons concerned.

If the information received gives reasonable grounds to believe that a criminal offence, administrative offence, or another violation has been planned, is being committed, or has been committed, such information will be immediately forwarded to the competent authority without the consent of the reporting person, and the reporting person will be informed accordingly.

Our obligations:

Company undertakes to review all information received impartially and in accordance with applicable legal requirements. We also ensure that:

• confidentiality of your identity and personal data will be protected;
• you will not be subjected to retaliation (including dismissal, suspension, reassignment, harassment, termination of contract, or similar adverse treatment);
• you will not incur any liability or obligation to compensate damages if you reasonably believe that the information provided is true;
• you will be provided with guidance regarding reporting procedures and available legal remedies.

Please note that whistleblower status under the Law on the Protection of Whistleblowers is granted by the Prosecutor's Office of the Republic of Lithuania. The Company does not decide on the granting of whistleblower status.

If Company fails to comply with the obligations described above, you have the right to apply to a competent authority or court.

More information on reporting and whistleblower protection is available on the website of the Prosecutor's Office of the Republic of Lithuania.