INDICATOR: 2-26

The Code of Conduct provides for the possibility of providing advice on ethical and legal conduct and the possibility of anonymous reports to the Regulatory Compliance Office, with full confidentiality and discretion. Under Chapter 6 of the Code of Conduct, a conflict-of-interest issue arises when our personal relationships, outside activities or interests in other businesses influence or could influence an employee’s decisions of any kind in the performance of his or her duties. When these situations arise is a question of fact and must be dealt with on a case-by-case basis. Moreover, sometimes this conflict between a person or a member of his or her family and the interests of the group is not easily perceived, as there are cases that create confusion and doubt. The Regulatory Compliance Office assesses the cases brought to its attention as to whether they constitute an existing or potential conflict of interest and provides instructions for the removal of the conflict if it is found to exist. The Parent Company intends to adopt a conflict-of-interest prevention policy which will form part of the Code of Conduct.

The Code of Conduct provides for the option for employees of the Group and third parties dealing with the Group to report to the Regulatory Compliance Office any conduct that may deviate from the law, the Code, the Group’s Policies and Regulations or that they are in doubt as to whether it complies with them. There is also the option of making an anonymous report. The Regulatory Compliance Office investigates the validity of the reports in a confidential and confidential manner and recommends appropriate corrective measures in the event that the content of the report is assessed as valid. The Regulatory Compliance Office, at its discretion, cooperates with other Group Divisions for the evaluation and investigation of reports (e.g. Internal Audit Division or Human Resources Division).

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 revised Code of Conduct is expected to come into force in 2024, as part of the broader revision of the corporate governance system so that it complies with the latest legislative developments, mainly regarding corporate governance, the prevention and suppression of money laundering and anti-corruption. At the same time, the protection of persons who report or disclose information obtained in an employment context and relating to illegal acts (whistleblowing) is strengthened and the extension of communication channels for reporting infringements is foreseen. 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.

EKO Bulgaria

The reporting mechanisms and related competence procedures are described in the Code of Conduct.

The internal rules on prevention of corruption provide for the procedure of anonymous reporting by the company’s employees related to suspected money laundering or terrorist financing.

In accordance with the Complaints Regulation, the company has implemented an internal reporting channel that provides confidential means of communication for reporting relevant violations.

EKO Serbia

Any employee who encounters the described situation shall inform his/her supervisor, who in turn shall inform the Director responsible.

Any supplier who identifies the described violation shall inform the partner in the relevant department or the manager of the department responsible.

Jugopetrol

The Group’s services, executives and employees should be supported by the Group’s Legal Service in case they have any doubts or need clarification regarding the legality of their actions in the performance of their duties.

OKTA

The Group has a mechanism in place to protect labor rights, as required by law. It has developed measures and procedures for protection against harassment in the workplace.

A mechanism has been implemented to protect the personal data of our customers and employees, and the rights of our employees, as required by law. The Group has implemented measures and procedures for the security of company assets. In addition, there is a team of representatives appointed for Health and Safety issues with defined responsibilities based on legislation. Regular training is offered to new contractors, truck drivers and employees regarding health, safety and environmental issues and internal procedures. An independent Internal Audit Division is operational.