Anti-Corruption Policy

ANTI-CORRUPTION AND BRIBERY POLICY

 

1.    Purpose

The purpose of this is to guide KAFSIS executives and employees, as well as third parties that interact with KAFSIS, in order to comply with applicable anti-corruption legislation and more generally to promote a culture of ethics and integrity.

 

2.    Application

This procedure applies to all KAFSIS activities, the company's employees and all third parties involved in the company's activities.

 

3.    Records

ODESLO adheres to the following::

 

4.    Procedure

The procedure for dealing with corruption is implemented as follows:

 

4.1   General

The fight against corruption, including bribery and extortion, is one of KAFSIS' priorities. KAFSIS.

ODESLO has identified the relevant risks, having carried out an analytical risk assessment and has defined preventive and corrective measures to address corruption and bribery phenomena. KAFSIS Management declares its full commitment and determination to implement the measures, adopting a zero-tolerance policy for such phenomena.

 

4.2   Definitions

Anti-corruption legislation:

Any legislation at National or Community level that concerns corruption, such as the following indicative, non-limiting, mentioned:

·         · Law 4472/2017 (Government Gazette A 74 - 19.05.2017)

·         · Law 4506/2017 (Government Gazette A 191 - 12.12.2017)

·         · Law 4509/2017 (Government Gazette A 201 - 22.12.2017)

·         · Law 4512/2017 (Government Gazette A 5 - 17.01.2018)

·         · Law 4320/2015 (Government Gazette 29 19.03.2015)

·         · Law 4325/2015 (Government Gazette 47 11.05.2015)

·         · Law 4370/2016 (Government Gazette 37 - 07.03.2016)

·         · Law 4389/2016 (Government Gazette 94 - 27.05.2016]

·         · Law 4446/2016 (Government Gazette 240-22.12.2016)

·         · Law 4478/2017 (Government Gazette 91 - 23.06.2017)

·         · Law 4619/2019 (Government Gazette A 95 - 11.06.2019)                                                              

 

Anything of value

'May include, but is not limited to, the following:

·         · Money (cash)

·         · Gifts

·         · Accommodation, Meals, Entertainment

·         · Travel expenses

·         · Services

·         · Job offer

·         · Loans

·         · Donations

·         Anything of value, including nominal value

 

Code of Conduct:

The Code of Conduct of KAFSIS as defined in the Code of Conduct.

Bribery:

The payment of anything of value to any Public Entity, Public Official or Private Entity acting on behalf of the Public (Consultant) with the aim of securing for KAFSIS resources, contracts, or an unfair advantage over competition.

 

Person

Any natural person.

 

Joint Venture / Partnership

Entity in which KAFSIS participates as a shareholder, as a member or as a partner, the policy and actions of which KAFSIS determines or influences directly or indirectly.

 

Third Parties

Natural or legal persons operating on behalf of or for the benefit of KAFSIS, such as consultants, suppliers, subcontractors, etc.

 

 

4.3   KAFSIS Policy Against Corruption and Bribery

KAFSIS, its employees and Third Parties are prohibited from offering, delivering or promising anything of value to any Person to influence decisions or actions of such Person or the Entity it represents, with the ultimate purpose of unfairly securing a contract, retaining a contract, or obtaining any unfair advantage over the competition.

 

4.3.1  Gifts, Donations, Hospitality, Sponsorships

The company may make donations to local/regional associations to provide assistance. However, it does not make donations to organizations where a relative or government official works. Furthermore, a donation is not made if the financial support can bring some kind of benefit to the company sought by the sponsorship. Finally, if the organization lacks financial transparency, the company does not allow financial sponsorship. The company condemns donations to political parties or candidates for political office.

 

4.3.2 Expenses

 

  The company may make purchases and transactions that serve the good functioning of the company and its interests. Expenses must be controlled by the competent department and approved by Senior Management in order to ensure financial transparency. Proof of payment for meals, trips, gifts must be submitted to the competent department and evaluated. The principles governing the company are against money laundering and anything that implies acts of bribery.

 

 

4.3.3 Bonus Payment

 

According to the Approved Internal Operating Regulations (2015), all employees are entitled to the agreed remuneration based on the services they provided and the contracts signed with the company upon commencement of employment, as well as the state legislative frameworks in force. Extraordinary special allowances (Bonus or gifts) may be awarded due to quantitative or qualitative performance, good behavior and conduct, however, in no case should they be given with the suspicion of assuming any obligation.

 

4.3.4 Conflict of Interest

 

To avoid conflicts of interest, employees must select partners and suppliers with objective criteria without being influenced by personal biases or interests. In addition, they must notify the Management of any relatives or individuals from their social circle with whom the company does business and who may have a conflict or influence of interest with the company. Furthermore, each employee must not take advantage of their role in the company in order to obtain favorable treatment and benefits from external partners, public bodies, suppliers with whom the company collaborates.

 

 

 

4.4   Preventive actions

KAFSIS takes all measures to prevent any acts of corruption in which the company, its executives, employees and/or Third Parties are involved. More specifically: · KAFSIS informs all employees, Management executives and Third Parties about the anti-corruption and bribery policy it has adopted. · KAFSIS incorporates the anti-corruption and bribery policy as a condition in all contracts and/or other documents of undertaking duties or obligation to perform work, with the aforementioned entities. · Instructions and training to the company's employees to deal with any incidents of corruption.

 

 

4.5   Detection of violation

Corruption incidents, due to their nature, usually become known through complaints. For this reason, KAFSIS offers the possibility of anonymous reporting on a special form (Bribery Complaint Form) posted on the company's website. After the complaint, the Anti-Bribery System Manager (ABS) in collaboration with ODESLO investigates whether the complaints are justified in order to proceed with their immediate response and makes the relevant report to the Senior Management. Employees have the right to directly address the Anti-Bribery Committee or other bodies such as the National Transparency Authority. No employee will be sanctioned for refusing to participate in acts of bribery or bribery, nor for suspicions of bribery submitted through a complaint.

 

 

4.6   Dealing with corruption incidents

In the event of a complaint or detection of a corruption incident involving a member of the Management and/or an employee of KAFSIS and/or a Third Party, the ODSO immediately informs the Company's Management and all necessary measures are taken in cooperation with the Company's Legal Department, in order to: · check whether any complaint is substantiated and whether the involvement of the reported Person or Entity related to KAFSIS is confirmed. · clarify the Company's policy and stance towards entities that are affected or generally affected by corruption actions. · KAFSIS to cooperate fully with state authorities and contribute to the procedures for assigning responsibilities by the competent state bodies. · KAFSIS to take the necessary measures to terminate or reform the relationship / cooperation with the Person or Entity that has proven to have violated the legislation and the company's policy on combating corruption.

 

 

4.7   Monitoring

In order to monitor KAFSIS's performance in combating corruption, a record is kept of cases of complaints and identification of corruption incidents, a brief description of the complaint, confirmation or denial of the complainant's allegations, the measures and actions taken by KAFSIS to address the incidents..