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, which at the same time the Group is drafting a detailed Whistleblowing Policy, in compliance to the recently voted Law 4990/2022, which incorporated the EU Dierctive 1937/2019 on the protection of whistleblowers.
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, before their registration, 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.
The Operating Regulations, the Operating Manual and the form ‘Vision, Strategy, Principles’ of the Group’s Internal Audit Department have been updated, on the occasion of the new Law on Corporate Governance (Law 4706/2020) that came into force on 7/2021 and imposed changes in the organization, operation and responsibilities of the Internal Audit units.
In accordance with the Internal Audit Standards, the Group’s General Internal Audit Division is assessed every 5 years by an independent, external certified assessor. The purpose of the assessment is to validate whether the Internal Audit Activity conform with the Standards and whether the Internal Auditors apply the Code of Conduct. Moreover the GIAD is assessed every three years according to the Corporate Governance Law (4706/2020), as part of the assessment of the System if Internal Controls. In 2023, both of the abovementioned assessments will take place.
New suppliers are informed by email, before their registration, 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.
Business relationships are reviewed during the due diligence process by risk category. GIAD, 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).