Whistleblowing Policy

This policy deals with specific complaints regarding the infringement of policies and procedures of the Company / its subsidiaries or violations of the applicable laws (e.g. incompliance with the Code of Conduct, policies, financial statements matters, employee relations, abuses, discrimination, corruption, theft, money laundering, any misconduct which could harm the reputation of the company, or any attempts to conceal any of the above).

According to the above policy, the employees or third parties may report to the Compliance Office, either signed or anonymously, any concern or any complaint regarding violations of the policies / the legislation.
In case of reporting a complaint giving your name, we ensure the fact that there is no retaliation for the whistleblower..

CONFIDENTIALITY:

Do you have to report a behavior that may expose the Company to a risk? Do you feel uncomfortable to reveal the information?

We guarantee that through this application we will provide you confidentiality because all disclosures, signed or anonymous, are treated as sensitive. Nevertheless, before submitting a complaint (Tip-off), please keep in mind that the information you provide can have significant consequences for those involved.

Nevertheless, you have to take into consideration the fact that in case your complaint involves certain persons, the subjects of the personal data in process, by exercising their rights of notification, access and objection according to the articles 11 to 13 of the law 2472/1997, are entitled to become informed about the complaint and the relevant pieces of evidence.

We note that if your complaint refers to individuals it should not contain elements which are sensitive personal data ( i.e. data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health, social welfare and sexual life, criminal prosecutions or convictions).

PERSONAL DATA PROTECTION:

The most important principle of the Whistleblowing Policy is the protection of the whistleblower, with the exception of a malicious tip – off.

The present application protects your identity because you do not fill in any specific information data that may reveal your identity. We are only interested in the information provided by you regarding the incidents, and not finding your identity.

In case of a malicious complaint, the accused person is entitled to request the data regarding the identity of the whistleblower in order to exercise its legal rights.

USE OF THE ELECTRONIC WHISTLEBLOWING FORM:
You should know that when you report a complaint anonymously, we are not able to contact you in order to gather more information to sustain the investigation.

Please do not use this Whistleblowing channel for customer complaints regarding the products and services of the Company. This type of complaints will be addressed to the Customer Care.

DISCLAIMER ABOUT THE SECURITY of the ANONYMOUS WHISTLEBLOWING FORM:
The present application shall protect your anonymity.

In case of an anonymous complaint, please follow the below instructions:

• do not specify personal data such as name or your relationship with those involved,
• do not provide any data that may reveal your identity,
• use a secure internet connection.

If you wish to remain anonymous, please do not give us information that might help to identify you. You should know that when you report a complaint anonymously, we are not able to contact you in order to gather more information to sustain the investigation. Therefore please give us all the details necessary to initiate an investigation or an e-mail address to allow us to contact you without being able to identify you.