Privacy Policy

Last updated: May 02, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to UAB Autologa, Betygalos str. 4A, Kaunas, LT-47183, Lithuania.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: Lithuania
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Autologa, accessible from it.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • Phone number
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies. Type: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies. Type: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies. Type: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: To manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: The development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us by email: info@autologa.lt

Supplier Code of Conduct

Document version No. 1
Director 2025-10-31

UAB “Autologa” Supplier Code of Conduct

UAB “Autologa” strives to be the first choice for all customers looking for storage and interior design solutions that help maintain order in the home and create a more pleasant environment.
We strive to achieve this by using high-quality, innovative production methods, services and solutions that add value to our customers. Resources must be used in sustainable, socially and environmentally responsible ways.

To build trust and ensure the implementation of Corporate Social Responsibility ( CSR ) throughout our operations value chain, including suppliers, we ask all our suppliers to agree to comply with our Supplier Code of Conduct.

The Supplier Code of Conduct sets out the minimum standards that are expected of all suppliers of UAB “Autologa”. Within its sphere of influence, UAB “Autologa” also expects suppliers to apply these minimum standards to their subcontractors and sub-suppliers. In addition, suppliers are expected to always strive to comply with the best international and industry practices.

Suppliers are expected to comply with the laws, rules and regulations of all countries in which they operate.

We, UAB “Autologa”, expect that the Supplier Code of Conduct will be followed, but we recognize that the application of these basic principles is a dynamic, not a static process and encourages suppliers to support our goal and constantly seek ways to improve.

In order to be able to demonstrate and present the work done and the progress made in implementing the specified principles, the supplier is expected to implement the necessary internal measures (e.g. assessment procedures, tools and indicators).

A third party appointed by UAB “Autologa” has the right to conduct inspections or audits at the company’s site in order to assess the supplier’s progress in implementing the specified principles.

All employees of UAB “Autologa” working with suppliers are obliged to ensure that suppliers are familiar with the Supplier Code of Conduct and understand its content.

Workers and human rights

Suppliers must respect the human rights of workers, treat them with dignity and respect, as understood by the international community.

Fighting discrimination

Suppliers shall not discriminate against employees on the basis of race, color, age, gender, sexual orientation, ethnicity, disability, religion, political opinion, union membership, national origin, or marital status in employment and labor relations, such as in hiring, promotion, compensation, training opportunities, job assignments, wage determination, benefits, disciplinary action, and termination decisions. Suppliers shall not require employees or potential employees to undergo medical examinations that could be used to discriminate against them, except when such examinations are required by applicable law or regulation or to ensure the safety of employees in the workplace.

Honest behavior

Suppliers shall strive to ensure that the workplace is free from harassment. Suppliers shall not threaten employees or use cruel and inhumane treatment, including sexual harassment, sexual assault, physical punishment, psychological abuse, physical abuse, verbal abuse, or unreasonable restrictions on access to or exit from company premises. Suppliers shall prohibit harassment and unlawful discrimination in the workplace.

Prevention of forced labor and human trafficking

Suppliers do not engage in human trafficking or engage in any form of slavery, forced, compulsory or involuntary servitude, or any other form of forced or compulsory labor that restricts a person’s freedom. This includes the transportation, harboring, recruitment, transfer or receipt of persons by means of the threat, use of force, coercion, abduction, fraud or payment to another person over the control of another person, for the purpose of exploitation. All work must be voluntary, and workers have the right to freely resign or terminate their employment with due notice. Workers may not be required to surrender government-issued identification documents, passports or work permits as a condition of employment.

Prevention of child labor

Child labor is strictly prohibited. Suppliers shall not employ children and shall take appropriate measures to ensure that child labor is not used at their production or operation site(s) or at the production or operation site(s) of subcontractors. The minimum age of workers shall be 15 years, the minimum age for employment in the country or the age of completion of primary school, whichever is higher. Suppliers shall obtain documents that legally prove the dates of birth of all their workers. Suppliers shall maintain a register of such records. This Code does not prohibit participation in legal apprenticeship programs that comply with Article 6 of ILO Convention No. 138 on Minimum Age, or the employment of light labor that complies with Article 7 of ILO Convention No. 138 on Minimum Age.

Protection of young workers

Suppliers may employ young workers who are above the legal minimum age for employment but under 18 years of age, provided that they are not engaged in work that is likely to endanger their health, safety or morals, in accordance with ILO Convention No. 138 on Minimum Age.

Working hours, salary and benefits

Except in exceptional or unforeseen circumstances, the workweek, including overtime, shall not exceed 60 hours, and employees shall have at least one day off every seven days. Under no circumstances shall the workweek exceed the maximum workweek permitted by applicable laws and regulations. Suppliers shall pay all employees at least the minimum wage required by applicable laws and regulations and shall provide all legally required benefits. In addition to compensation for regular hours worked, overtime shall be paid at least the minimum wage required by applicable laws and regulations.

Employees are paid at the rate provided for in applicable laws and other legal acts.

Suppliers shall not use deductions from wages as a disciplinary measure. Suppliers shall provide vacation, days off, and sick leave in accordance with applicable laws and regulations. Suppliers shall use a transparent and reliable system for recording working hours and wages and shall pay employees on time, clearly indicating the basis for payment of wages. Suppliers shall also provide all employees with accident insurance that covers medical services in the event of a work-related accident.

Freedom of assembly and association

Suppliers shall respect the right of workers to freely associate, to form and join workers’ organizations of their choice, to seek representation and to bargain collectively, as permitted by applicable laws and regulations. Suppliers shall not obstruct the establishment, operation and administration of workers’ organizations, as provided for in applicable laws and regulations.

Safety and health

UAB “Autologa” recognizes that integrating good health and safety management practices into all aspects of the business is essential to maintaining high morale and producing innovative products. Suppliers provide safe working conditions and a healthy working environment for all their employees.

Workplace injury prevention

Suppliers shall, where possible, eliminate physical hazards. Where physical hazards cannot be eliminated, suppliers shall ensure that appropriate engineering controls are in place, such as physical guards, locks and barriers. Where engineering controls are not feasible, suppliers shall establish appropriate administrative controls, such as safe work procedures. In all cases, suppliers shall provide workers with appropriate personal protective equipment. Workers shall not be subject to disciplinary action for raising safety concerns and shall have the right to refuse to work in unsafe working conditions without fear of retaliation until their concerns are adequately addressed by management.

Prevention of chemical exposure

Suppliers shall identify, assess and control worker exposure to hazardous chemical, biological and physical agents. Suppliers shall eliminate chemical hazards where possible. Where chemical hazards cannot be eliminated, suppliers shall use appropriate engineering controls such as enclosures and ventilation. Where engineering controls are not possible, suppliers shall ensure appropriate administrative controls such as safe work procedures. In all cases, suppliers shall provide workers with appropriate personal protective equipment.

Accident prevention, preparedness and response

Suppliers anticipate, identify and assess emergencies and incidents and mitigate their impact by implementing emergency plans and emergency response procedures, including emergency notification, employee awareness and evacuation procedures, employee training and drills, appropriate first aid measures, appropriate fire detection and suppression equipment, appropriate exits and business recovery plans.

Occupational safety procedures and systems

Suppliers shall establish procedures and systems for the management, monitoring and reporting of work-related injuries and occupational illnesses.
Such procedures and systems encourage employees to report injuries and illnesses, classify and record them, investigate incidents and implement corrective actions to address their causes, ensure the provision of necessary medical care and facilitate employees’ return to work.

Ergonomics

Suppliers identify, assess and control physically demanding tasks, including heavy lifting and highly repetitive or strenuous assembly tasks.

Household and dining rooms

Suppliers shall provide workers with clean toilets, access to potable water, and food preparation and storage facilities. Living quarters provided to workers by the supplier or third-party agency shall be clean and safe, have adequate emergency access, adequate heating and ventilation, provide workers with sufficient personal space, and appropriate entry and exit privileges.

Providing information on safety and health

In order to create a safe working environment, suppliers shall provide employees with appropriate health and safety information and training, including written health and safety information and appropriate warnings, in the primary language of their employees. Suppliers shall post Material Safety Data Sheets (MSDSs) in the primary language of their employees for hazardous or toxic substances used in the workplace and shall provide appropriate training to employees who will be exposed to such substances in the workplace. Records of such training shall be maintained, including the names of participants, dates of training, and content of training.

Employee health and safety committees

Suppliers are encouraged to initiate and support the establishment of employee health and safety committees to enhance ongoing education on health and safety issues and encourage employee input into addressing health and safety issues in the workplace.

Environmental impact and responsible energy use

At UAB “Autologa”, environmental protection and energy use issues are an integral part of business practices. Suppliers are committed to reducing the environmental impact of their design, production processes and waste disposal and to saving energy.

Management and restrictions of substances of concern.

Suppliers shall comply with all applicable laws and regulations, such as REACH1 and RoHS2, that prohibit or restrict the use or handling of specific substances. To ensure safe handling, transfer, storage, recycling, reuse and disposal, suppliers shall identify, manage and list substances of concern as required by the Pelly Group entity (any such substances shall be reported using the established response form) and comply with applicable labeling laws and regulations applicable to design, manufacture, recycling and disposal.

  1. EU Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals.
  2. Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment

Solid waste management

Suppliers manage non-hazardous solid waste generated during operations as required by applicable laws and regulations.

Wastewater and rainwater management

Suppliers monitor, control and treat wastewater generated during operations before discharge, as required by applicable laws and regulations. Suppliers take appropriate precautions to prevent stormwater runoff from entering the company’s facilities.

Air emissions management

Suppliers shall characterize, monitor, control and treat airborne volatile organic compounds, aerosols, corrosives, particulates, ozone-depleting chemicals and combustion by-products generated during operations before they are released into the air, as required by applicable laws and regulations.

Land pollution

Suppliers ensure compliance with applicable laws and regulations related to land pollution. Suppliers investigate and assess potential land contamination risks from past or ongoing activities.

Environmental permits and reporting

Suppliers must obtain and maintain all required environmental permits (e.g. emission monitoring) and registrations and comply with the operational and reporting requirements set out in such permits.

Pollution prevention and resource reduction

Suppliers shall strive to reduce or eliminate solid waste, wastewater and air emissions, including energy-related indirect air emissions and substances contained in products, by implementing appropriate safeguards in their manufacturing, maintenance and facility processes, recycling, reusing or replacing materials used. UAB “Autologa” recognizes that integrating good health and safety management practices into all aspects of the business is essential to maintaining high morale and producing innovative products. Suppliers shall provide safe working conditions and a healthy working environment for all their employees.

UAB “Autologa” undertakes to implement the activities in order to ensure compliance with the requirements of ISO/IEC 27001 and TISAX standards; to ensure compliance with the directives of the European Parliament and the Council, EU environmental and energy laws and other requirements.

Suppliers must demonstrate a fair, appropriate approach to ensuring quality, environmental protection and energy conservation.

To ensure continuous improvement of the Supplier’s energy efficiency and effectiveness, and to use all types of energy resources sustainably and rationally. To supply raw materials, materials, products and services that are produced in an energy-efficient manner.

To periodically participate in supplier assessments organized by UAB “Autologa”, to cooperate in a mutually beneficial manner and to strive for energy saving and sustainability.

Ethics

Suppliers must adhere to the highest ethical standards in their dealings with employees, suppliers and customers.

Business integrity

Suppliers shall not violate international anti-corruption conventions, applicable anti-corruption laws and other legal acts in force in the countries in which they operate, and shall not in any way participate in corrupt, extortion or other forms of embezzlement activities. Suppliers shall adhere to fair business standards in advertising, sales and competition. Suppliers shall maintain high ethical standards, in particular by complying with this Supplier Code of Conduct and good business practices. Suppliers are expected to avoid conflicts of interest that may undermine the supplier’s credibility within the Pelly Group or the trust of other external parties in the Pelly Group. An example of such a conflict of interest is if the supplier is a member of an association whose core values conflict with those of the Pelly Group.

Gifts and hospitality

Suppliers are expected not to give or accept inappropriate gifts or gifts that could be considered improper compensation in order to obtain, retain or directly conduct business or to secure any other improper advantage for the supplier in conducting business with UAB “Autologa”. Such inappropriate gifts (bribes, etc.) include money, items, entertainment trips, extravagant meals or other services.

Gifts must meet the following requirements:

  • The gift must be legal under local laws, regulations and policies.
  • The gift must have a clear and legitimate business purpose.
  • A gift cannot be given in exchange for an improper advantage.
  • The nature, value and frequency of gifts must be appropriate to the occasion.
  • The gift must be given transparently.

Disclosure of information

Suppliers must accurately record and disclose information about their business activities, structure, financial condition and performance in accordance with applicable laws and regulations and prevailing industry practices.

Whistleblower protection and anonymous complaints

Suppliers shall develop and implement programs that ensure the confidentiality of whistleblowers – both supplier and employee – and prohibit retaliation against employees who voluntarily participate in such programs or refuse to accept direction that violates the Pelly Group Supplier Code of Conduct. Suppliers shall utilize an anonymous grievance mechanism through which employees may report workplace misconduct in accordance with local laws and regulations.

Community engagement

Suppliers are encouraged to engage the community by promoting social and economic development and contributing to the sustainability of the communities in which they operate.

Intellectual property protection

Suppliers must respect intellectual property rights and protect customer information. Transfer of technology and know-how must be carried out in a manner that protects intellectual property rights.

Communication, information security, personal data protection

Communication channels

Email:

  • Use only organization-approved email addresses (not personal ones).
  • Confidential information should only be sent via encrypted email (e.g. S/MIME or PGP) or another secure channel agreed upon with the organization.

File transfer:

  • Only secure file transfer tools such as SFTP, MFT, or other organization-approved platforms are allowed.
  • It is prohibited to send confidential data via public cloud services (e.g. WeTransfer, Google Drive) unless expressly approved in writing.

Video conferencing and chats:

  • Use only approved communication tools (e.g. Microsoft Teams, Webex, Zoom with business accounts).
  • Confidential information should not be shared with unauthorized persons during meetings.

Access control

Persons participating in the communication must be authenticated and have the necessary access permissions.

The supplier must ensure that only authorized personnel have access to communication channels related to our organization.

Information classification and labeling

All transmitted information must be marked according to its level of confidentiality (e.g., “Confidential”, “Internal”, “Public”). Confidential information is transmitted with the following label: Confidential.

The supplier must comply with these markings and protect the information accordingly.

Incident management

The supplier must immediately (within 24 hours) inform our organization of any communication security breach, unauthorized access or data leak.

The incident report must include at least: description of the event, date/time, systems affected, and action taken.

Responsibility and monitoring

Our organization has the right to inspect the supplier’s communication security measures.

The supplier must cooperate during the audit or inspection and provide requested evidence (e.g. logs, policy documents).

Training and awareness

Supplier employees who work with our information must be trained on information security and TISAX requirements.

Training must be updated periodically (at least once a year).

Compliance with the provisions of the Personal Data Regulation

In the event that it is necessary to exchange personal data information, a separate GDPR agreement will be concluded;

Information security, cybersecurity:

Cooperate and participate in the investigation of the incident;

Information should only be exchanged securely, encrypted and/or transmitted via a secure channel.

Store and transfer data in accordance with ISO 27001, TISAX, legislation, the Cybersecurity Act; In accordance with the requirements of the Data Protection Regulation. Comply with the listed legislation and standards.

Communication interruption

At the end of the collaboration, the supplier must ensure that all communication channels are closed, access is revoked, and data is securely destroyed or returned.

In the event of a breach of confidential information or non-compliance with communications, an investigation into the incident or event is immediately initiated, and measures are taken to ensure information security and communications.

The organization may claim compensation for damages when it is legally confirmed.

Management commitments

Suppliers must implement or develop a management system that ensures compliance with this Code and applicable laws and regulations, identifies and mitigates risks associated with operations, and enables continuous improvement. Useful resources include ISO 14001, ISO 9001, ISO 27001, TISAX. Management commitments should include the following elements:

Company statement

A corporate social and environmental responsibility statement confirming the Supplier’s commitment to compliance and continuous improvement, which must be posted in the primary local language at all locations of the Supplier’s operations.

Management accountability and responsibility

Clearly identified company representatives responsible for the implementation and periodic status review of supplier management systems.

  • Risk assessment and management – the process of identifying the risks associated with business operations in the areas of environmental, health and safety, business ethics, labour, human rights and legal compliance. The relative significance of each risk is determined and appropriate procedures and physical controls are implemented to ensure compliance and control of the risks identified. The health and safety risk assessment should cover warehouses and storage areas, plant and plant support equipment, laboratories and testing areas, bathrooms, kitchens, cafeterias and employee living areas.
  • Performance objectives with implementation plans and measures – written standards, performance goals, objectives and implementation plans, including periodic assessment of the supplier’s performance against these goals.
  • Audits and assessments – periodic assessments of our own activities and procedures to ensure that the supplier, its subcontractors and downstream suppliers comply with this code and that they are kept up to date in accordance with relevant applicable laws and regulations.

Documents and registration

Supplier shall have a documented procedure to identify, monitor and understand applicable laws and regulations and the additional requirements set forth in this Code. Supplier shall obtain, maintain and regularly renew a business license as required by applicable laws and regulations. Supplier shall have documented and record-keeping processes to ensure compliance with laws and regulations and compliance with this Code, using appropriate confidentiality measures to protect privacy.

Training and communication

Suppliers must have approved programs to train managers and employees on how to implement policies and procedures to achieve improvement goals. Suppliers must have approved procedures to communicate clear and accurate information about operations, practices, and expectations to employees, suppliers, and customers.

Employee feedback

Suppliers shall have approved procedures for obtaining ongoing feedback on processes and practices related to the implementation of this Code, thereby promoting continuous improvement.

Corrective action process

The supplier must have approved procedures for the timely correction of any deficiencies identified during an internal or external audit, assessment, inspection, investigation or review.

UAB “Autologa” – a company providing pharmaceutical logistics (forwarding) services. This document describes what the companies of the UAB “Autologa” group of companies (hereinafter referred to as UAB “Autologa” companies) consider to be the main requirements for their suppliers in the field of road freight transport activities and which the company itself adheres to in carrying out its daily activities and ensuring the smooth functioning of the supply chain.

All companies of UAB “Autologa” comply with all laws and legal acts in force in the different countries in which they operate, as well as this code.

The Code of Conduct and Social Responsibility of UAB “Autologa” suppliers (hereinafter referred to as the Code) defines the basic principles of the activities of UAB “Autologa” suppliers.

  • When selecting suppliers, UAB “Autologa” companies must make every effort to select suppliers with a good reputation who are guided by UAB “Autologa” companies’ ethical standards and business practices that comply with ethical standards.
  • This Code defines the practices of UAB “Autologa” companies and clearly establishes that, recognizing cultural and legal differences, we expect our suppliers to produce goods and provide services in accordance with high standards that are consistent with the excellent reputation of UAB “Autologa” companies, regardless of where the suppliers are located, produce goods for us, components used in our goods and provide services to us. Suppliers must comply with this Code and good business practices.
  • The Code applies to all suppliers of UAB “Autologa” (hereinafter referred to as “suppliers of UAB “Autologa”).
  • UAB “Autologa” companies strongly encourage their suppliers to adhere to high standards, and to apply best practices and promote continuous improvement in their activities. If local legislation does not provide for such a requirement or if the requirement of local legislation is not as strict as that provided for in this Code, suppliers of UAB “Autologa” companies must comply with the requirement of this Code in order to work with UAB “Autologa” companies.

Laws and regulations

  • Suppliers of UAB “Autologa” must comply with all laws and legal acts in force in the countries in which they operate, as well as this Code.

Child labor

  • Suppliers of UAB “Autologa” companies must comply with local laws establishing the minimum age of employees. UAB “Autologa” companies do not tolerate child employment.
  • Suppliers of UAB “Autologa” must comply with all legal requirements and applicable laws defining the legal employment of young workers, especially requirements regarding their working hours, wages, health and safety, working conditions, and work with certain materials.

Forced labor

  • Suppliers of UAB “Autologa” may not use involuntary or forced labor, including indentured labor , debt bondage, prison labor, bonded labor, or labor from victims of human trafficking.

Harassment

  • Suppliers of UAB “Autologa” must treat all their employees with respect and dignity. Corporal punishment, physical, psychological, sexual or verbal harassment , stalking  or violence are unacceptable.

Penalties

  • UAB “Autologa” suppliers do not apply monetary fines as disciplinary sanctions, except in cases where local laws allow it.

Salary and benefits

  • UAB “Autologa”‘s suppliers must pay their employees no less than the minimum wage established by local laws and provide all legally required benefits. In addition to wages for regular working hours, employees must be paid for overtime at the rates established by local laws, and if there are no such laws in the countries, at a rate no lower than the rate for such employees’ regular working hours.

Working hours

  • UAB “Autologa”‘s suppliers must ensure that their employees work in accordance with local laws on regular work and overtime. The supplier’s drivers work in accordance with the general provisions on driving and rest times for drivers established by European laws.

Employee health and safety

  • Suppliers of UAB “Autologa” companies must ensure a clean, safe and healthy working environment for their employees, which meets all legally binding health and safety standards in the countries where the suppliers operate. They must also prevent work-related injuries and illnesses of employees and eliminate OSH risks by taking effective prevention and protection measures. This also applies to all accommodation provided by UAB “Autologa” suppliers to their employees. Suppliers of UAB “Autologa” companies are obliged to properly instruct and train their employees in health and safety issues.

Discrimination

  • Suppliers of UAB “Autologa” must ensure that employment relationships, including employment, wages, benefits, promotions, termination of employment, and retirement, are based on skills, not beliefs or other personal characteristics.
  • UAB “Autologa” does not tolerate direct and indirect discrimination of employees. UAB “Autologa”‘s suppliers undertake to adhere to the principles of equal opportunities and not to discriminate against employees based on their gender, race, nationality, language, origin, social security, faith, beliefs or views, age, sexual orientation, disability, ethnicity or religion.

Labor, human and equal opportunity rights

  • Suppliers of UAB “Autologa” must ensure that all employees are treated equally in all aspects of employment relations, gender, and human rights.
  • Employees of UAB “Autologa” suppliers must have the right to free trade unions, workers’ councils or other joint associations that would ensure that employers respect legal requirements for the working environment, minimum working hours, wages, and payment of taxes.

Environmental awareness, social responsibility

  • Suppliers of UAB “Autologa” companies must comply with all local environmental protection laws that apply to the workplace, manufactured goods and production methods, protect the environment by preventing or reducing negative environmental impacts.

In addition, suppliers of UAB “Autologa” may not use environmentally harmful and hazardous substances and should promote the use of environmentally friendly processes and materials, and reduce their generation. It is desirable that the supplier takes care of:

  • Reduce environmental pollution and CO2 emissions;
  • Encourage and sort waste yourself;
  • Involve our employees and business partners in promoting environmental protection and new initiatives;
  • Integrate environmental protection criteria when selecting suppliers of services or goods;
  • Conserve water and electricity to reduce energy consumption.

UAB “Autologa” companies encourage suppliers to participate in initiatives and activities related to the United Nations Sustainable Development Goals, and to take active steps to reduce negative environmental impacts throughout the supply chain, and to apply the requirements of the Good Distribution Practice Guidelines.

Business continuity planning

  • UAB “Autologa”‘s suppliers must be prepared for any disruptions to their business (i.e. natural disasters, terrorism, IT hacking, cyberattacks, infectious disease outbreaks). This preparedness includes business continuity plans that will protect both employees and the environment from potential incidents that may arise in the field of operations.

Business integrity (bribery)

  • Suppliers of UAB “Autologa” must comply with bribery prevention, i.e. not to give or accept bribes under any circumstances.

Fair competition

  • Suppliers of UAB “Autologa” must adhere to the prevention of fair competition, i.e. illegal agreements with customers, suppliers or state institutions are prohibited.
  • Suppliers must not engage in any anti-competitive activities, such as price agreements between manufacturers, restrictions on the sale of goods, market sharing, etc.

Safe driving

  • UAB “Autologa” carriers (subcontractors) must take care of their drivers’ safe driving education and training. Pay close attention to the continuous improvement of drivers’ driving skills, organize safe and eco-driving training.
  • UAB “Autologa” companies’ carriers (subcontractors) must ensure the prevention of the use of alcohol and other psychoactive substances in their company, and take strict measures to ensure that their employees are sober and responsible for their actions during work.
  • UAB “Autologa” carriers (subcontractors) must ensure that they take preventive measures to promote the fight against prostitution, human trafficking, sexual exploitation, and illegal transportation of people for reward, and consider such actions to be criminal.

Personal data protection and information security

  • Suppliers of UAB “Autologa” companies must apply all requirements and provisions of the EU Personal Data Protection Regulation and information security in their activities.
  • Suppliers of UAB “Autologa” companies must have approved internal personal data protection rules, in which the collection, recording, use, and storage of personal data comply with the requirements of the laws regulating the protection of personal data.
  • Suppliers of UAB “Autologa” companies must ensure that their companies ensure a high level of information security and control and comply with the basic principles of information protection.
  • Suppliers of UAB “Autologa” companies undertake not to disclose confidential information of UAB “Autologa” companies to third parties and to adhere to the “need to know” principle.

Informing

  • Suppliers of UAB “Autologa” must inform related parties about this Code and its provisions as needed.
  • UAB “Autologa” companies should take all necessary corrective actions and immediately correct any identified non-compliance. UAB “Autologa” companies reserve the right to terminate business relations with a supplier of UAB “Autologa” companies that is unwilling or unable to comply with this Code, if permitted by local laws.

Implementation of the Code

  • UAB “Autologa” companies reserve the right to verify whether the companies’ suppliers meet the requirements of this “Supplier Code of Conduct and Social Responsibility”. The document should be used as a guideline.

Questions

If you have encountered or have any doubts regarding this document, are unsure how to act in a certain situation, or have any complaints related to the implementation of this Code, it is advisable to contact your contact person or email: info@autologa.lt

INTEGRATED MANAGEMENT SYSTEM POLICY

Document version No. 1
Director 2025-05-06

As part of our company’s operations, we provide electronic equipment acquisition and disposal solutions for businesses.

By improving the quality of the company’s management and service provision processes, in order to ensure the successful and targeted development of the company, as well as a stable and competitive position in the market, we undertake to:

to carry out activities in accordance with the legal acts of the Republic of Lithuania regulating the business sector and other requirements that the organization undertakes to implement, aiming for compliance with ISO 9001:2015; ISO 9001:2015/AMD1:2024; ISO 14001:2015, ISO/IEC 27001:2022, ISO 14001:2015/AMD1:2024, ISO/IEC 27001:2022/AMD1:2024, TISAX Level 2 (AL 2);

  • standards, directives GDPR, NIS 2, TIS 2, DI, TIS Level 2 (AL 2), IS strategy and other requirements;
  • The company is committed to ensuring the confidentiality, integrity and availability of information (CIA) during all processes;
  • Management assumes responsibility for information security management and appoints an Information Security Manager (ISM) responsible for the implementation of TISAX and IVS.
  • The organization identifies and classifies information and IT assets according to confidentiality levels (public, internal confidential, restricted confidential, and secret).
  • Access to information is granted on a least privilege and need-to-know basis .
  • Access rights of employees and partners are regularly reviewed and changed upon their departure.
  • Partners and suppliers are assessed for security before being granted access to systems or data. Confidentiality and data protection agreements (NDAs) are concluded with them .
  • Access to the premises is restricted, physical security measures are in place (control mechanisms, visitor registration, equipment protection;
  • Confidential data is stored and transmitted using encryption tools, and backup copies are also made;
  • to continuously improve the effectiveness of the management system, taking into account performance results, feedback from customers, partners and employees;
  • constantly improve ongoing relationships with our partners and suppliers, stakeholders;
  • promote employee qualification development in the areas of Information Security, Cybersecurity and other areas;
  • to introduce innovations and seek solutions to improve the quality of service provision;
  • to guarantee safe and healthy working conditions for employees, to help employees understand their own responsibility for protecting their own safety and health and that of others, to ensure safe and healthy working conditions, to commit to eliminating hazards, to commit employees to consulting and participating in health and safety activities;
  • identification, management and implementation of risk mitigation actions, continuous improvement of information security risks and threats;
  • to raise environmental awareness among employees, to prevent pollution by safely and responsibly managing waste;
  • implementation of climate change initiatives, management of sustainability strategy;
  • information technology supply chain management;
  • Ensuring project management and quality, as well as time, safety and other project criteria;
  • rational use of energy and natural resources;
  • cyber attack threat management; continuous timely response to incidents;
  • implement preventive measures for events and incidents;
  • this policy is reviewed at least once a year , internal audits, tests and TISAX assessments are performed;
  • Incidents are recorded and investigated, and critical incidents are reported to partners no later than within 24 hours ;
  • Work equipment is used for company purposes only. It is prohibited to use personal devices to process information related to customers or partners without permission;
  • to continuously improve the effectiveness of the integrated management system, taking into account performance results, employee suggestions, and customer and partner feedback.

Our goal and commitment is to provide our clients with services that comply with ISO 9001:2015; ISO 9001:2015/AMD1:2024; ISO 14001:2015, ISO/IEC 27001:2022, ISO 14001:2015/AMD1:2024, ISO/IEC 27001:2022/AMD1:2024, TISAX Level 2 (AL 2) and the requirements regulated by legal acts.

The IMS policy is reviewed and updated as needed.