1. Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and anti-corruption regulations, and that the Company's activities are conducted in a socially responsible manner.
2. Policy statement
Bribery is the offering, promising, giving, accepting or seeking of an advantage as an inducement for an illegal action or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
It is our policy to conduct all our activities in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and to implementing and enforcing effective systems to counter bribery.
We will comply with all laws relating to the fight against bribery and corruption in every jurisdiction in which we operate. However, we remain bound by the laws of Greece in respect of our conduct both at home and abroad.
Bribery and corruption are punishable for individuals by imprisonment and a fine. If we were found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and suffer damage to our reputation. We therefore take our legal responsibilities very seriously.
We are committed to meeting all the requirements of the standard ELOT EN ISO 37001:2017 and to the continual improvement of the Anti-Bribery Management System.
3. Scope
3.1 Who is covered by the policy?
In this policy, a third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, suppliers, distributors, business contacts, consultants, government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all persons working at all levels and grades, including the Board of Directors, managers, employees (permanent, fixed-term or temporary), consultants, subcontractors, seconded staff, home workers, casual workers, sponsors or any other person associated with us, or any of our affiliated companies or their employees, wherever located (collectively referred to as employees in this policy).
This policy covers:
Bribery
Gifts and hospitality
Facilitation payments
Political contributions
Charitable contributions
3.2 Bribery
Employees must not engage in any form of bribery, whether directly or through any third party (such as an agent or distributor). Particular care is exercised in relation to Public Officials.
3.3 Gifts and hospitality
Employees must not offer or give any gift or hospitality:
which could be regarded as illegal or improper, or which violates the policies of the recipient, or
to any public official or government officials or representatives, or politicians or political parties, or
which exceeds €100 in value for any single gift or €500 in value for any single instance of hospitality (not to exceed a total value of €1,000 in any financial year), unless approved in writing by the employee's manager.
Employees may not accept any gift or hospitality from our business partners if:
it exceeds €100 in value for any single gift or €500 in value for any single instance of hospitality (not to exceed a total of €1,000 in any financial year), unless approved in writing by the employee's manager, or
it is in cash, or
there is any suggestion that a return favour will be expected or implied.
Where a manager's approval is required, it must always be sought.
If it is not practical to decline the offer of a gift, the gift may be accepted, provided that it is subsequently declared to the employee's manager and donated to a charitable cause.
We appreciate that the practice of giving business gifts varies between countries and regions, and that what may be normal and acceptable in one region may not be in another. The test to be applied is whether, in all the circumstances, the gift or hospitality is reasonable and justified. The intention behind the gift must always be taken into account.
Within these parameters, Management may set out specific guidelines and policies to reflect professional and industry standards. Where this policy requires written approval to be given, these approvals are kept on file.
3.4 Facilitation payments and kickbacks
Facilitation payments are a form of bribery made with the purpose of expediting or facilitating the performance by an official of a routine public action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low-level officials in order to obtain a level of service to which one would normally be entitled in any case.
Our strict policy is that facilitation payments must not be made. We recognise, however, that our employees may find themselves in situations where there is a risk to the personal safety of an employee or their family and where a facilitation payment is unavoidable, in which case the following steps must be taken:
Keep any amount to the minimum,
Create a record concerning the payment, and
Report it to the immediate supervisor.
In order to achieve our goal of not making facilitation payments, the Company keeps a record of all payments, so that the business risk can be assessed and the strategy to minimise such payments can be facilitated.
3.5 Political contributions
We do not make donations, whether in cash or in kind, in support of any political parties or candidates, as this may be interpreted as an attempt to gain an improper business advantage.
3.6 Charitable contributions
Charitable support and donations are acceptable (and indeed encouraged), whether in the form of services in kind, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a vehicle to conceal bribery. We only make charitable donations that are legal and ethical under the applicable laws and practices. No donation must be offered or made without the prior approval of the compliance manager.
All charitable contributions should be publicly disclosed.
4. Your responsibilities
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those who work for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify the Compliance Manager as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with employees if they breach this policy.
5. Record keeping
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
You must ensure that all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No account must be kept “off-book” to facilitate or conceal improper payments.
6. How to raise a concern
We encourage you to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, you should discuss them with your immediate supervisor or the company's compliance manager.
7. What to do if you are a victim of bribery or corruption
It is important that you inform the Compliance Manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are the victim of another form of unlawful activity.
8. Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. Our aim is to encourage openness and to support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring that no one suffers detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or another corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered such treatment, you should inform the Compliance Officer immediately. If the matter is not remedied and you are an employee, you should raise it formally with the company's Management.
9. Training and communication
Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept compliance with this policy on an annual basis.
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and, as appropriate, thereafter.
10. Who is responsible for this policy?
The company's Manager has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Compliance Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, and dealing with any queries about its interpretation. Management at all levels is responsible for ensuring that those reporting to them are made aware of and understand this policy, and for providing adequate and regular training on it.
11. Monitoring and review
The Compliance Officer will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to ensure that they are effective in countering bribery and corruption.
All employees are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing.
Employees are invited to comment on this policy and to suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Compliance Officer.
This policy does not form part of any employee's contract of employment and it may be amended at any time.