INDICATOR: 2-23
Policy commitments
We are committed to being a responsible Group. This means that all our activities are conducted in accordance with relevant ethical, professional, technical and legal standards and regulations. Corruption, bribery, and unfair competition are unacceptable.
The Group’s Code of Conduct was approved and notified in 2011 (in Greek and English) with full implementation throughout the Group as well as extended to its external partners, who have been notified. The Code of Conduct is in the process of being evaluated and revised, which builds on experience gained from its implementation and incorporates new legislation.
The Group’s Competition Policy and Compliance Program were approved by the Board of Directors in 2018.
In addition, during 2018, the Group’s Privacy Policy was adopted in compliance with the applicable national and European regulatory framework, in particular the European General Data Protection Regulation (GDPR).
It is the Group’s goal to ensure in practice that the rules that must be followed and adopted as corporate behavior in each organizational unit of the Group are strictly observed. The revision of the Code of Conduct is in its final stage. At the same time, the protection of persons who report or disclose information obtained in the workplace concerning unlawful acts (whistleblowing) is strengthened and the channels of communication for reporting infringements are extended. In application of the provisions of Law 4990/2022 on the protection of persons who report violations of European Union law (Whistleblowing), the relevant Policy has been drawn up and is expected to be implemented immediately.
Similarly, the preparation of the Policy for Combating Violence and Harassment at Work was completed in 2022, in accordance with the provisions of Law 4808/2021.
The procedures for Health, Safety, Quality and the Environment – according to international standards – and corresponding policies are available on the corporate network (intranet and internet).
The Group’s Core Principles of Action, as outlined in the Code of Conduct, are binding for all employees at Group’s companies, in Greece and abroad.
The statements, codes or policies concerning procurement activities fall under the existing Purchasing Manual, paying special attention to cooperation with suppliers.
New suppliers are informed by email, prior to their inclusion in the registry, of the following Group principles and policies: HSE&SD Policy, Code of Conduct, Privacy Notice for Suppliers, United Nations Global Compact and Greek Sustainability Code.
According to the Internal Audit Standards, the Group’s Internal Audit Division is evaluated every five years by an independent external authorized assessor regarding the extent of Group compliance with the Global Internal Audit Standards. Additionally, the Group’s Internal Audit Division is assessed every three years according to the Corporate Governance Law (4706/2020) as part of the Internal Audit System evaluation. In 2023, both of the abovementioned assessments took place. It is noted that 70% of auditors of the Group Internal Audit Division are certified on Internal Audit issues.
Business relationships are reviewed during the due diligence process by risk category. The Internal Audit Division performs, within the scope of certain audit projects, audit steps where supplier evaluation forms are requested and checked whether relevant conditions are met (for example, human rights, environment, labor relations, etc).
Moreover, the Internal Audit Division will be conducting audits for the further investigation of matters arising for the whistleblowing process.