Internal messaging channel

Below is information on how you, using the internal whistleblowing channel of Amber Grid (hereinafter referred to as the Company), may provide information about violations of law prepared, committed or committed in the Company in accordance with the Law on the Protection of Whistleblowers of the Republic of Lithuania (hereinafter referred to as the Law).

A violation is considered to be a criminal offense, administrative offense, or breach of work duties, as well as a gross violation of mandatory professional ethics standards, that is being prepared, is being committed, or has been committed at the Company, a criminal offense, administrative offense, or violation of work duties, as well as a gross violation of mandatory professional ethics standards, an attempt to conceal the aforementioned violation, or other violations of the law that pose a threat to or violate the public interest, about which the person reporting the violation learns from their existing or potential employment or contractual relationship with the Company or during the recruitment or other pre-contractual relationship (hereinafter referred to as the Violation).

Information about Violations is provided in order to protect the public interest. You can use the internal reporting channel to provide information about violations related to:

• threats to public safety or health, or to human life or health;
• threats to the environment;
• obstruction or unlawful interference with investigations by law enforcement authorities or the administration of justice;
• illegal financing of activities;
• illegal or non-transparent use of public funds or property;
• illegally acquired property;
• concealment of the consequences of a violation, obstruction of the determination of the extent of the consequences;
• violations of competition law and state aid rules;
• violations of international sanctions implemented in the Republic of Lithuania or restrictive measures provided for in the laws of the Republic of Lithuania;

• other violations that harm the public interest.

A person providing information about a violation through an internal channel is not required to be completely certain about the accuracy of the reported facts, nor is he or she obliged to assess whether the violation being reported meets the criteria for criminal offenses or other violations of the law as defined in legislation.

IMPORTANT:

• The internal reporting channel is not intended for complaints, requests, or reports submitted to protect exclusively personal interests. Reports submitted to protect exclusively personal interests will not be investigated;
• To report violations other than those listed above, please use the Trust Line. Reports received through the Trust Line will not be considered reports submitted under the Law

REPORTING OF A BREACH

A person wishing to submit a notification under the Law may do so in the following ways:

• by contacting the competent entity of the Company directly in writing, by handing over or sending by post to the Company (Amber Grid, Laisvės pr. 10, Vilnius) the completed violation notification form. When sending a notification by post, the envelope containing information on the violation must be marked 'TO THE COMPETENT ENTITY PERSONALLY' under the addressee's name;
• orally, upon arrival at the Company (Laisvės pr. 10, Vilnius) at the competent entity;
• by sending information about the violation, by filling in the notification form, through the Company's internal channel for reporting violations – e-mail: apsauga@epsog.lt;
• by applying to the Prosecutor General's Office, the competent authority. The notification shall be submitted to the Prosecutor General's Office when:

1. the violation is of fundamental importance for the public interest;
2. it is necessary to prevent or bring an end to the violation as soon as possible, as serious damage may occur;
3. persons in management, employment or contractual relations with the Company may themselves commit or have committed violations;
4. information about the breach was provided through the internal whistleblowing channel, but no response was received or no action was taken in response to the information provided, or the measures taken were ineffective.
5. there are grounds to believe that the submission of information about a breach through an internal breach reporting channel may not ensure the anonymity of the whistleblower or the confidentiality of the person will be sought to conceal the reported breach;
6. The company does not have a functioning internal channel for the provision of information about violations;
7. the person cannot use the internal channel for the provision of information about violations, because he or she is no longer connected with the Company by work or other legal relations.

We recommend that you submit reports by filling out the violation notification form. The notification can also be submitted in free form, but it must contain the following information:

• who, when, in what manner and what violation he has committed, is doing or is about to commit, etc.;
• the date and circumstances in which the iviolation became known;
• your name, surname, personal identification number, place of employment, other contact details;
• where possible, provide any available documents, data or information revealing signs of a possible breach.

In the Company, the performance of the functions of the competent entity has been entrusted to:

• Head of Business Resilience Division Tomas Alekna, e-mail: T.Alekna@ambergrid.lt or phone: +370 612 70606;
• Business Security Expert Mindaugas Subačius, e-mail: M.Subacius@ambergrid.lt or phone: +370 635 65340.

RIGHTS AND GUARANTEES OF PERSONS PROVIDING INFORMATION ON BREACHES

From the moment of receipt of the notification, the confidentiality of the person and the prohibition of exerting a negative impact on them shall be ensured to the persons who have provided information about the violations, regardless of whether the person who submitted the notification of the violation to the Company has been recognized as a whistleblower or not.|

Confidentiality is ensured regardless of the results of the investigation of the information on the breach received.

Confidentiality is not necessary where:

• this is requested in writing by the person providing information about the violation;
• information provided by the person providing information about the violation is known to be false.

A person shall not be liable for any contractual or tortious liability for the provision of information about the violation, as well as liability for insult to honour and dignity, for defamation, if, while providing information about the violation in accordance with the procedure established by the Law, he reasonably believed that he was providing correct information.

A person shall be liable for damages caused by the provision of information about the violation only if it is proved that the person could not reasonably believe that the information provided by him was correct.

The submission of knowingly false information, as well as information constituting a state or official secret, does not provide guarantees to a person under the Law. A person who has provided knowingly false information or has disclosed a state or official secret or professional secret shall be liable in accordance with the procedure established by legal acts.

HANDLING OF REPORTS

Notifications received by the Company shall be examined in accordance with the procedure established by the Law and other legal acts.

Currently, the Company's internal legislation regulating the examination of notifications is being updated.