INDICATOR: 2-26
Mechanisms for seeking advice and raising concerns – Internal and external mechanisms for seeking advice on implementing policies and practices, as well as on integrity issues in the organization (eg helpdesk, ability to update higher levels of hierarchy, whistleblowing, support lines, etc.)
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 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 Directive 1937/2019 on the protection of whistleblowers.
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.
EKO Serbia
The Code of Conduct manages all these aspects and has been communicated to all employees, suppliers and customers.