| Responsible Person | an Employee appointed by the CEO of the Group Company responsible for coordinating and supervising the implementation of corruption prevention measures established in this Policy. |
| Group Companies | MAXIMA GRUPĖ, UAB and its directly and indirectly controlled legal entities. |
| Employee | a person employed in a Group Company under an employment contract, a civil contract, or performing duties or working on any other basis, including members of management, supervisory bodies, and committees, regardless of the form of their relationship with the respective company or whether they are remunerated. |
| Gift | a person employed in a Group Company under an employment contract, a civil contract, or performing duties or working on any other basis, including members of management, supervisory bodies, and committees, regardless of the form of their relationship with the respective company or whether they are remunerated. |
| Conflict of Interest | a situation where the private interests (for example, financial, political, family) of the Employee or his/her close relative may affect (determinate) actions taken on behalf of the Group Company (for example, when performing duties, making or participating in decisions, or carrying out an assignment). |
| Corruption | any activity involving the abuse of powers entrusted by the Group Companies for personal or any third-party benefit. Corruption in this Policy encompasses all its forms, including bribery, graft, trading in influence, facilitation payment, or other acts aimed at achieving a similar purpose. |
| Trust Line | an information reporting channel intended for reporting violations of legal acts committed, being committed, or intended to be committed in a Group company, including corruption-related violations. |
| Policy | this Corruption Prevention Policy. |
| Foreign State | any foreign country, except the country in which the Group Company operates, including all foreign institutions from the municipal to the national level. The concept of a foreign state also includes international organizations. |
| Foreign Public Official | xxxx |
