Latvijas Juras medicinas centrs

Governance Information • May 13, 2025

LATVIJAS JURAS MEDICINAS CENTRS JSC

Reg. Nr. 40003306807

CORPORATE GOVERNANCE REPORT FOR THE YEAR 2024

RIGA, 2025

CONTENTS

I PREPARATION OF THE STATEMENT	2
II PRINCIPLES OF GOOD CORPORATE GOVERNANCE	4
STRATEGY OF THE COMPANY	4
INTERNAL CULTURE AND ETHICAL CONDUCT	4
INTERNAL CONTROL SYSTEM, RISK MANAGEMENT AND INTERNAL AUDIT	5
ELECTION OF MEMBERS OF THE SUPERVISORY BOARD	6
PRINCIPLE FOR DETERMINATION OF REMUNERATION OF THE SUPERVISORY	8
COUNCIL AND MANAGEMENT BOARD	8
PREVENTION OF THE CONFLICT OF INTEREST 10
MEETING OF SHAREHOLDERS 10
TRANSPARENCY OF THE OPERATION OF THE COMPANY 13
Annex No.1: INFORMATION TO BE PUBLISHED ON THE WEBSITE OF THE COMPANY	13
Annex No.2: THE MOST IMPORTANT POLICIES OF THE COMPANY	15

PREPARATION OF THE STATMENT. LEGAL BASIS

The Corporate Governance Statement for 2024 (hereinafter referred to as - the Report) of the joint stock company Latvijas Jūras medicīnas centrs (hereinafter referred to as – LJMC or Company) is prepared upon fulfilling the requirements of Section 56.2 of Financial Instrument Market Law and on the basis of the Corporate Governance Code, issued by the Advisory Corporate Governance Council of the Ministry of Justice of the Republic of Latvia, developed in 2020. The Corporate Governance Code is available on the website of the Ministry of Justice of the Republic of Latvia www.tm.gov.lv.

The Statement on 2024 is prepared by the Management Board of the joint stock company Latvijas Jūras medicīnas centrs (hereinafter referred to as - the Board). The Statement is submitted to Nasdaq Riga together with the audited Annual Report of 2024, as well as is submitted on the website of the LJMCwww.ljmc.lv in sub-section 'Corporate Governance' along with other reports.

MANAGEMENT REPORT

Constant growth and financial indicators of JSC LJMC confirm that its corporate governance is effective and achieves the targets proposed. The Management Board of the JSC Latvijas Jūras medicīnas centrs has assessed the compliance of the capital company with the principles set forth in the Corporate Governance Code. Having assessed the governance system of the joint stock company as well as adherence of principles in 2024, the Management Board considers that in 2024 the JSC Latvijas Jūras medicīnas centrs has complied with the majority of the principles of corporate governance, as well as explains the reasons in the case if any of the principles is not complied with or is complied with partially.

Corporate Governance Statement of the JSC Latvijas Jūras medicīnas centrs for 2024 has been approved by the Management Board in Riga, on 30 April 2025.

Janis Birks Chairman of the Board Riga, April 30, 2025.

PRINCIPLES OF GOOD CORPORATE GOVERNANCE

STRATEGY OF THE COMPANY

Strategy of the Company is a significant tool by which targets of the company as well as progress to long-term success and value increase is determined.

Principle No.1

The Company has established current strategy, determining corporate targets and progress to the long-term value increase.

Criteria:

• 1.1. The company has current strategy, the draft of which is developed by the Board.
• 1.2. The Supervisory Council is involved in the development process of the strategy and approves the strategy during the meeting of the Supervisory Council.
• 1.3. The Supervisory Council monitors the implementation of the strategy.
• 1.4. The Management Board of the Company implements the strategy and regularly reports to the Supervisory Council on the course of implementation thereof.

LJMC partially complies with the principle, because the Supervisory Council is involved in the development process of the strategy, however, so far, a separate meeting of the Supervisory Council has not taken place, during which the strategy of the LJMC.

INTERNAL CULTURE AND ETHICAL CONDUCT

The core principles of the internal culture and ethical conduct of the Company and values that they are based on are preconditions for successful long-term development of the Company.

Principle No.2

The Company develops the Code of Internal Culture and Ethical Conduct, which shall serve as a standard of conduct for management and employees of the Company.

Criteria:

• 2.1. The Supervisory Council defines core values of the Company.
• 2.2. The Code of Internal Culture and Ethical Conduct is prepared by the Management Board and approved by the Supervisory Council.
• 2.3. The Management Board ensures compliance with the Code of Internal Culture and Ethical Conduct during daily activities of the Company and responds in case of establishment of a violation of the Code of Ethical Conduct.

LJMC partially ensures the compliance with this principle. The Company operates in accordance with several internal policies and procedures: Collective Employment Agreement, Quality Management Manual, , Anti-Corruption Policy, Date Protection Policy, Risk Management, Basic condictionsof Ethics and other internal documents.

The Company has defined its mission, vision and basic values.

INTERNAL CONTROL SYSTEM, RISK MANAGEMENT AND INTERNAL AUDIT

The purpose of the internal control system is to provide effective, sustainable and successful operation of the company, truth and compliance of the provided information with the relevant regulatory enactments and principles of operation.

The purpose of the risk management is to identify, assess, manage and control potential events or situations, in order to ensure assurance on the achievement of the strategical targets of the company.

The internal audit helps the company to achieve its objectives, implementing systematic processes, in order to assess and improve the efficiency of risk management, internal control and governance processes.

Principle No.3 The Company has internal control system, the efficiency of which is supervised by the Supervisory Council.

Criteria:

• 3.1. The Company has documented internal control system, the establishment of which is under the responsibility of the Management Board.
• 3.2. The internal audit conducts the efficiency assessment of the internal control system at least once per year, considering the pre-defined criteria, and reports the results of the assessment to the Supervisory Council.
• 3.3. The Supervisory Council evaluates the assessment provided on the efficiency of the internal control system at least once a year.

LJMC complies with this principle. The internal control processes of the Company are determined by several internal documents, including Quality Management Manual, Risk Management and other

Principle No.4

The Company identifies, assesses and supervises the risks related to its operation.

Criteria:

.

• 4.1. The Risk Management Policy of the Company is developed by the Management Board and approved by the Supervisory Council.
• 4.2. On the basis of the assessment of identified risks, the Management Board implements the risk management measures.
• 4.3. At least once a year the Supervisory Council reviews the management reports on risk management measures and implementation of the risk management policy.

LJMC complies with this principle. Jointly working with the Supervisory Council of LJMC, the Company has developed the Risk Management Policy that is used by the Company in order to implement risk management measures.

Principle No.5

The Company has established an internal audit company department, which is independently and objectively assessing the activities of the Company.

Criteria:

• 5.1. The Company has an internal auditor, who is functionally independent from the Management Board and reports to the Supervisory Council.
• 5.2. The internal auditor is appointed by the Supervisory Council.
• 5.3. The internal auditor develops an internal audit plan based on risks, which is approved by the Supervisory Council.
• 5.4. The internal auditor informs the Management Board and the Supervisory Council on the fulfilment of the internal audit plan, audit results and recommended activities for elimination of shortages, if any are established.

LJMC The principle may not be followed, but the functions of the Audit Committee are delegated to the Council, which is elected by the Shareholders' Meeting. The Council prepares the Audit Committee's report based on the information received from the Board (corporate governance principles, budget planning, preparation of annual reports, internal control, risk management), as well as other internal documents.

EXTERNAL AUDITOR

The external auditor provides an independent report on the financial position of the Company, credibility and compliance of financial statements with requirements of regulatory enactments to the Management Board and Supervisory Council, all shareholders and investors, creditors and other stakeholders.

Principle No.6

The Company has an independent external auditor.

Criteria:

• 6.1. The Supervisory Council and Audit Committee, if any is established, determine the criteria for selection of the external auditor.
• 6.2. The Company has an independent external auditor with the relevant qualification.
• 6.3. Period of authority of one external auditor does not exceed 5 years.

LJMC partially complies with this principle. The Meeting of Shareholders has approved an independent external auditor with the relevant qualification - SIA KPMG Baltic, which is one of the leading auditor companies in Latvia and provides involvement of an independent sworn auditor in accordance with the procedure provided by regulatory enactments.

ELECTION OF MEMBERS OF THE SUPERVISORY BOARD

Competent and experienced Supervisory Council is a pre-condition for efficient operation of the Company and decision making, facilitating the long-term value increase of the Company The Supervisory Council works in the interests of all shareholders and the Company.

Principle No.7

The Company ensures transparent procedure for election and revocation of members of the Supervisory Council.

Criteria:

• 7.1. The Company has approved the procedure for selection and revocation of members of the Supervisory Council.
• 7.2. The Company provides timely and sufficient information to shareholders of the Company on members of the Supervisory Council, who are proposed for election or re-election.
• 7.3. The size of the Supervisory Council corresponds to work specifics of the Company.
• 7.4. A member of the Supervisory Council is elected for a time period not longer than 5 years.

LJMC complies with this principle. Candidates of members of the Supervisory Council are selected on the basis of the professionalism and competence criteria. Members of the Supervisory Council are appointed and revoked by the Meeting of Shareholders.

Principle No.8

Members of the Supervisory Council has relevant experience and competence.

Criteria:

• 8.1. The Supervisory Council in general has the set of skills, experience and knowledge, including about the relevant field, in order to be able to fully perform their duties.
• 8.2. When establishing the composition of the Supervisory Council, the principles of diversity are obeyed.
• 8.3. Both genders are represented in the Supervisory Council.
• 8.4. The Management Board develops the introductory training programme and provides introductory trainings to the new members of the Supervisory Council.

LJMC partially ensures the compliance with this principle. Principles of diversity are complied, which is proved by experience of members of the Supervisory Council in different fields; all members of the Supervisory Council are the professionals of the highest level. More detailed information on members of the Supervisory Council is available in the website of the Company, in the section 'For Shareholders'.

Principle No.9

The Supervisory Council of the Company has independent members of the Supervisory Council.

Criteria:

• 9.1. The Company assesses and shareholders determine the proportion of independent members of the Supervisory Council.
• 9.2. At least half of members of the Supervisory Council are independent.
• 9.3. Candidates for independent members of the Supervisory Council submit a certificate on the compliance with the criteria of independence.
• 9.4. Before elections of the Supervisory Council the Company performs independence assessment of the members of the Supervisory Council in accordance with the available information.

LJMC complies with this principle. During the reporting period, five members of the Council of the Company operate, who have confirmed their willingness to assume the duties of a Council member with their signature, ensuring compliance with independence criteria in accordance with the Commercial Law norms and examples of best practice.

PRINCIPLE FOR DETERMINATION OF REMUNERATION OF THE SUPERVISORY COUNCIL AND MANAGEMENT BOARD

Clearly defined principles for remuneration of members of the Supervisory Council and Members of the Board promote transparency of use of funds and effective risk management.

Principle No. 10 Remuneration policy is introduced in the Company.

Criteria:

• 10.1. The Company has introduced the remuneration policy, which is developed by the Management Board, reviewed by the Supervisory Board and approved by the Meeting of Shareholders.
• 10.2. Once a year the Supervisory Council determines the financial and non-financial targets to be achieved by the Management Board, their impact on the variable part of the remuneration and control their fulfilment.
• 10.3. Variable part of the remuneration is not determined as well as no compensation is paid to members of the Supervisory Council in case of revocation from the office or discharge from the office.
• 10.4. Once a year the report on remuneration granted to each current and former member of the Management Board and Supervisory Council is prepared.

LJMC fully complies with this principle. The Company has introduced the remuneration policy reviewed by the Supervisory Council and approved by the Meeting of Shareholders. Remuneration for performance of the duties of the member of the Management Board is determined under the decision of the Supervisory Council. Once a year a report on pay-out of remuneration is prepared.

WORK ORGANIZATION AND DECISION MAKING OF THE SUPERVISORY COUNCIL

Certain and comprehensive work organization of the Supervisory Council and availability of timely, high-quality and relevant information facilitate effective fulfilment of tasks of the Supervisory Council and full involvement of members of the Supervisory Council in decisionmaking.

Principle No.11

The Company has certain and understandable work organization of the Supervisory Council.

Criteria:

11.1. The Supervisory Council organizes its work in accordance with the Regulation and work calendar of the Supervisory Council.

• 11.2. The Supervisory Council holds at least one separate meeting of the Supervisory Council during a year for discussion of the strategy of the Company and fulfilment thereof.
• 11.3. The budget of the Company provides for funding necessary for provision of operation of the Supervisory Council.
• 11.4. Once a year the Supervisory Council conducts self-assessment of work of the Supervisory Council and its results are reviewed during the meeting of the Supervisory Council.
• 11.5. The Supervisory Council has assessed the need to establish committees (if a committee is established, see the principle #12.1).

LJMC partially complies with this principle. Rights and obligations of the Supervisory Board of LJMC are determined in the Charter of LJMC, Commercial Law, as well as included in the decisions of the Meeting of Shareholders, Supervisory Council and other documents. Charter of LJMC is available in the office of LJMC, in the Register of Enterprises of the Republic of Latvia and on the website of LJMC.

In 2024, the Supervisory Council of LJMC regularly contacted with the Management Board in order to discuss the most important issues related to the operation and development strategy, business activities and risk management of LJMC. The electronic communication means were also used in case of need for performance of functions of the Supervisory Council.

Principle No.12 Supervisory Council adopts well informed and considered decisions.

Criteria:

• 12.1. Information prepared by the Management Board for decision-making is available to the Supervisory Council in a timely manner and sufficient amount.
• 12.2. The Supervisory Council determines the procedure for information circulation, as well as the rights of the Supervisory Council to request the information from the Management Board, which is required for the Supervisory Council for decisionmaking.
• 12.3. A member of the Supervisory Council analyses information and prepares recommendations for decision making by the Supervisory Council.
• 12.4. When making decisions, the Supervisory Council assesses risks, short-term and longterm impact on the value, sustainability and responsible development of the Company.

LJMC complies with this principle. All necessary information for operation of the Supervisory Council is prepared in a timely manner. Information includes both, summary of the current situation as well as estimate on how the particular issue could affect the operation of the Company.

Principle No.12.1

The Committee prepares recommendations for decision making by the Supervisory Council.

Criteria:

• 12.1.1. The Supervisory Council determines the tasks and procedure for organization of the operation of the Committee.
• 12.1.2. The Supervisory Council establishes a Committee composed of at least 3 members of the Supervisory Council with the relevant experience and knowledge in the certain area of operation of the Committee (remuneration, nomination, audit or any other area).
• 12.1.3. The Committee analyses information and prepares recommendations for decision making by the Supervisory Council, as well as informs the Supervisory Council on the work of the Committee.

LJMC fails to comply with this criterion. Supervisory Council of LJMC consists of five members of the Supervisory Council and, having assessed the necessity for establishment of commissions, it was concluded that such number of people is optimum, without establishing separate committees for the Supervisory Council.

PREVENTION OF THE CONFLICT OF INTEREST

Gathering information and management of possible situations of conflict of interest reduces the financial and reputation risks of the Company.

Principle No.13

Members of the Management Board and Supervisory Council are clearly aware of the forms of conflict of interest and are informed on the necessary behaviour in case of conflict of interest.

Criteria:

• 13.1. The Supervisory Council defines the signs indicating on the conflict of interest and determines the procedure for prevention and management of conflict of interest.
• 13.2. Members of the Supervisory Council or Management Board do not participate in decisionmaking on the issues, where interests of the Company conflict with the interests of members of the Supervisory Council, Management Board or persons related to them.
• 13.3. Persons subject to the obligation of prevention of conflict of interest shall regularly participate in trainings on the way of acting in the situations of conflict of interest.

LJMC complies with this principle. The Company has defined procedure for identification, prevention and management of conflicts of interest. Members of the Supervisory Council or Management Board do not participate in decision-making on the issues, where interests of the Company conflict with the interests of members of the Supervisory Council, Management Board or persons related to them. Trainings for members of the Management Board and Supervisory Council are held periodically; in 2024 such trainings were not planned.

MEETING OF SHAREHOLDERS

Effective involvement of shareholders in decision-making helps to achieve the financial and nonfinancial targets of the Company as well as provides sustainable operation of the Company.

Principle No.14

The Company provides information to the shareholders on the course of the Meeting of Shareholders in a timely manner, providing all necessary information for decisionmaking.

Criteria:

• 14.1. The Company informs shareholders in a timely manner regarding the agenda, course of the Meeting of Shareholders and voting procedure, as well as any changes related to that.
• 14.2. At the same time with announcement of the meeting, the Company shall provide a possibility for shareholders to become acquainted with draft decisions, regarding which it was initially planned to vote during the meeting. The Company informs shareholders without delay on additional submitted draft decisions.
• 14.3. The Company provides shareholders with the possibility to submit questions about the issues included in the agenda and draft decisions before the Meeting of Shareholders.
• 14.4. Draft decisions and the enclosed documents provide detailed, clear and complete information on the issue to be discussed.

LJMC ensures the compliance with this principle. In 2024, one Meeting of Shareholders was held, which was announced in accordance with the procedure and within the time periods determined by legal acts. In 2024 LJMC disclosed the information in accordance with the requirements of the Financial Instrument Market Law and Regulations of JSC Nasdaq Riga. LJMC announced the Meeting of Shareholders at least 30 days in advance, at first posting the information in Latvian and English in the Official Mandatory Information Centralized Storage System and website of JSC Nasdaq Riga www.nasdaqbaltic.com, afterwards publishing a notification on convocation of the Meeting of Shareholders on the website of LJMC www.ljmc.lv and sending the information to JSC Latvian Central Depository. LJMC ensured availability of the authorisation form in the electronic form as well as ensured that the authorisation form is available in the Official Mandatory Information Centralized Storage System and website of JSC Nasdaq Riga www.nasdaqbaltic.com and website of LJMC www.ljmc.lv also afterwards when the notification on the Meeting of Shareholders is given.

Draft decisions of the Meeting of Shareholders were published at least 14 days before the Meeting of Shareholders in Latvian and English in the Official Mandatory Information Centralized Storage System, website of JSC Nasdaq Riga and LJMC. In addition, LJMC indicated that shareholders can become acquainted with the draft decisions on the issues to be discussed during the Meeting of Shareholders and recommendations on the issues included in the agenda of the Meeting of Shareholders from 28 May to 5 June 2024, on the working days.

Principle No.15

The Company performs effective involvement of shareholders in decision-making and possibly bigger participation of shareholders during the Meetings of Shareholders.

Criteria:

• 15.1. The Meeting of Shareholders is convoked and held at the place and time convenient for shareholders.
• 15.2. The Company ensures the possibility of shareholders to participate in the Meeting of Shareholders remotely.
• 15.3. The Company determines the relevant duration of the Meeting of Shareholders and gives an opportunity to shareholders to provide their opinion during the Meeting of Shareholders and to obtain necessary information for decision making.
• 15.4. The Company announces a new Meeting of Shareholders if it is not possible to discuss the issues included in the agenda of the meeting.
• 15.5. The Company invites the members of the Management Board and Supervisory Council, candidates for members of the Supervisory Council, auditors and internal auditors, as well as other persons to participate in the Meeting of Shareholders in accordance with the issues to be discussed during the meeting.
• 15.6. The Meeting of Shareholders makes decisions in accordance with the previously announced draft decisions.

LJMC ensures the compliance with this principle. In 2024, the Meeting of Shareholders was held in the premises of the office of LJMC, at the legal address of LJMC during the working hours. The place and time of the Meeting of Shareholders did not limit arrival of shareholders for the meeting. In 2024, LJMC did not change the place and time of the Meeting of Shareholders. Meetings are organized in a way to have access to information both, before the meeting as well as during the meeting, and was explained as per the need. The chair of the meeting was elected during the Meetings of Shareholders of LJMC in accordance with the Commercial Law proposed to determine the procedure (regulation) for discussion of issues of the Meeting of Shareholders and decision making, which was in force only when the Meeting of Shareholders approved it by majority of votes. LJMC does not limit the rights of shareholders to consult between them during the meeting in case if it is necessary for adoption of any decision or establishment of the issue, as well as to ask questions to the present representatives of LJMC. In order to protect health of shareholders, employees of the Company and management bodies and their candidates, the members of the management bodies of the Company were recommended to assess the need of their presence during the meeting and its proportionality with provision of public health and public interests in general.

Principle No.16 The Company develops and discusses with shareholders the Dividend Policy.

Criteria:

16.1. The Company has developed and published updated Dividend policy. 16.2. The Dividend Policy is discussed with shareholders during the Meeting of Shareholders.

LJMC fails to comply with this principle. The Company has not developed the Dividend Policy. In accordance with the Charter of LJMC, all shares have equal right to receipt of dividends. Distribution of profit is the issue of competence of the Meeting of Shareholders and shareholders vote for it.

TRANSPARENCY OF THE OPERATION OF THE COMPANY

Transparency of the operation of the Company serves as basis for effective relations with investors and successful communication with shareholders and other stakeholders.

Principle No.17

The Company regularly and in a timely manner informs shareholders and other stakeholders on the commercial activity, financial results, governance and other topical issues of the Company.

Criteria:

• 17.1. The Company discloses complete, accurate, objective, updated and true information in a timely manner.
• 17.2. The Company discloses the information to all shareholders at the same time and in the same scope.
• 17.3. The Company discloses information on the website on corporate governance, strategy or directions of operations and publishes financial statements as well as other information in accordance with Annex No.1.
• 17.4. The Company provides the information both, in Latvian as well as in at least on other language, which is understandable to the majority of the foreign shareholders of the Company and other stakeholders.

LJMC partially complies with this principle, because the Company has not published completely all documents referred to in Annex No.2 - The most important policies of the Company. LJMC publishes information in a timely manner on its website www.ljmc.lv, on the website of the Official Mandatory Information Centralized Storage System csri.investinfo.lv and website of the joint stock company Nasdaq Riga www.nasdaqbaltic.com.

Annex No.1: INFORMATION TO BE PUBLISHED ON THE WEBSITE OF THE COMPANY

Company:

• Information on the Company its establishment and operations history, registration data, address, description of the industry, key types of commercial activity, position of the Company in the organization chart (if applicable).
• Information on the strategical objectives of the Company.
• Charter of the Company.
• Information on the structure of the corporate governance of the Company (interaction between the Meeting of Shareholders, Supervisory Council, its committees, Management Board, auditor, internal auditor, Audit Committee etc.).
• Code of Internal Culture and Ethical Conduct of the Company.
• The most important policies of the Company in accordance with Annex No.2.

Shareholders and beneficial owners:

• Information on shareholders of the Company, who own at least 5% of the equity capital of the Company (specifying the date, when the information is prepared).
• Information on beneficial owners of the Company (specifying the date, when the information is prepared).
• Number of issued, paid or entitled to vote shares, bonds or other financial instruments.

Supervisory Council and Management Board:

• Regulation of the Management Board and Supervisory Council or any other document equal to that.
• Information on every member of the Supervisory Council and Management Board of the Company:
  • o period of authority;
  • o office and area of responsibility (if any determined); o professional work experience and education; o current information on offices held in other companies; o current information on shares of the Company owned; o statistics on attendance of the meetings of the Supervisory Council.
• Information on independent members of the Supervisory Council:
  • o which members of the Supervisory Council are to be considered independent; o according to what criteria the independence of a member of the Supervisory Council is determined; o annual assessment of independence of members of the Supervisory Council.
• Remuneration Policy and remuneration report of the Management Board and the Supervisory Council.
• Information on the selection (nomination) process of the Management Board and Supervisory Council.
• Information on the committees of the Supervisory Council and the Audit Committee:
  • o Regulation of the Committee; o information on members of committees.

Financial and non-financial statements and information:

• Financial statements and reports of the Company for at least the recent 3 financial years: o annual reports (including consolidated reports, if any prepared) and auditor's reports (if any prepared); o Interim reports and quarterly reports.
• Corporate Governance Statements.
• Financial calendar of the Company or calendar of any other significant and planned communication events.

Information to shareholders and investors:

• Information on the planned Meetings of Shareholders:
  • o notifications regarding convocation of Meetings of Shareholders; o draft decisions.
• Information on the held Meetings of Shareholders:
  • o Information on the decisions made during the Meetings of Shareholders.

Annex No.2: THE MOST IMPORTANT POLICIES OF THE COMPANY

The most important policies included in the corporate governance principles or criteria:

• Risk Management Policy. For identification, assessment, management and control of potentially negative events, in order to ensure assurance on achievement of strategical objectives of the Company.
• Remuneration Policy. For determination of remuneration on the basis of professional performance, as well as proportionality and compliance with the current economical situation, market practice, amount of remuneration in the field, as well as amounts of remuneration of employees of the Company.

Other most important policies mentioned in the Corporate Governance Code:

• Internal Audit Policy. For assessment and improvement of efficiency of the internal control, risk management and corporate governance processes.
• Policy on Prevention of Conflicts of Interest. For gathering information, management and elimination of situations, which conflict with the personal and professional interests or in case of a conflict between two opposing professional interests.
• Disclosure, Movement and Confidentiality Policy. For categorization of information and management of its movement, in order to ensure transparency of operation of the Company.
• Whistleblowing Policy. For timely identification and elimination of risks before a harm is caused to the reputation and shareholders of the Company, establishing environment, when employees can safely report on the established violations.

Significant Means of Compliance Policies:

• Personal Data Processing Policy. For compliance with the requirements of personal data protection, determining the procedure for data processing, including when performing data collection, organization, storage, viewing, use, disclosure, erasure, transmission, distribution or otherwise making them available.