Code of Ethics and Conduct
In the context of Corporate Social Responsibility, the Company has established policies and takes actions aimed at addressing environmental and social issues.

Purpose
The Company’s Code of Ethics and Conduct sets out our core corporate values. The Code outlines guidelines for proper employee conduct, to help employees identify ethics and compliance issues, before they arise, and deal with them appropriately, when they do arise.
The Code is communicated and applied by all employees, executives, managers, suppliers and partners of the Company. It defines the Company’s standards for ethical business conduct. These ethical business standards concern the relationships / transactions with the Company’s employees, customers, suppliers and partners as well as its shareholders, society and government authorities wherever it operates.
The Company’s Fundamental Principles
The fundamental principles of the Company are the principles that govern the behavior and relations between employees. They define how we behave inside and outside the Company. Everyone is responsible for conforming their behavior to our core values.


Compliance with Applicable Legislation
The Company in any case complies with the current legislation of the State.
Obedience to the Law is the foundation upon which the Company’s ethical standards are based. All employees and associates must obey and comply with applicable law in the conduct of their business activities. Although employees do not need to know the details of every applicable law and regulation, it is important that they are aware of this information which will lead them to seek advice from their supervisors, managers or other relevant personnel.
Free Will of Employees
The Company does not use any form of imposed or forced labor.
Working Conditions
The Company undertakes to take all those actions required to improve working conditions, health and safety, in order to ensure the protection of life and health of employees, including partners, subcontractors, and visitors to the Company’s premises, as defined by the written provisions of Greek and European legislation. Employees receive training on health and safety matters in work.

Work of Minors / Children
The Company does not hire as employees people with an age younger than the legally prescribed age.
Employment Relations – Employee Renumeration – Working Hours
Regarding matters of employment, recruitment, remuneration and benefits, training, promotion, transfer and termination of cooperation, each employee is treated as he should, according to the law applicable in each case.
The process of selecting and hiring employees is based on objective criteria, but also on principles and rules that ensure transparency and an objective assessment of the candidate. Jobs are associated with a fair wage, so that the worker is happy and his maximum efficiency is ensured.
The Company recognizes the right to rest and free time and follows national legislation regarding mandatory leave days, pregnancy and labor leave days, as well as other leaves related to family obligations or cases of force majeure.
Avoiding Discrimination
The Company takes every possible measure to avoid discrimination based on race, religion, color, origin, age, special needs, sexual orientation, political beliefs, gender or family status in all company procedures (recruitment, promotion, dismissal, training, etc. . .).
Lifelong Learning
The Company offers its employees training and development opportunities through training programs and seminars, as well as on-the-job training.
Avoid Harassment and Violence
No employee should be subjected to physical, sexual, racial, psychological, verbal or any other form of harassment or violence. Every employee must immediately report to the Management any incident (violation of basic rights, use of force or harassment) that comes to his attention.
Information Security
The Company has a Secure Information Management system and expects its employees to follow all applicable information security laws and relevant regulations.
Alcohol and Drugs
The Company is committed to maintaining a healthy work environment free of illegal substances. All employees must fully comply with the Company’s policies regarding alcohol abuse and the possession, sale and use of illegal substances.
The consumption of alcohol during working hours or within the Company’s facilities is prohibited, unless it is for specific events that take place after approval by the Management.
Reporting Any Illegal or Unethical Conduct
Employees are encouraged to report to their superiors, managers, Management, or the Information Security Officer for, as the case may be, the best possible response to phenomena of established or possible or suspected violations of the Code of Ethics and Conduct, company policy, or applicable Legislation. It is the Company’s policy not to allow retaliation or adverse treatment, by third parties, of employees who make such reports in good faith. Also, employees must cooperate during an internal investigation of such phenomena.
Right to Participate in Collective Actions
The Company recognizes the right of its employees to be represented by trade unions or workers’ committees, without this right to incur retaliation, while at the same time it provides facilities for the exercise of this right.
BUSINESS INTEGRITY AND ETHICS
Bribes
The Company does not give or receive, directly or indirectly, bribes with the aim of business or financial gain. No employee shall offer or receive any gift or payment that constitutes, or may be construed to constitute, a bribe. Any demand to receive or offer a bribe must be rejected immediately and reported to Management.
Financial Management
The integrity of the Company’s accounting and financial records is based on the accuracy and completeness of basic registrations of information in the Company’s accounting books. All those involved in the creation, processing and recording of this information are held responsible for its integrity. Each accounting or financial entry should accurately reflect the information described in the relevant items.
Protection of Personal Information
The Company respects the human dignity and personal data of its employees. The Company collects and maintains personal information only to the extent necessary for business or legal purposes. It complies with all applicable legislation which govern the retention and processing of employees’ personal data. Employee consent is required for the release of any additional information that may be requested by third parties.
Resources – Confidential Information
Company employees must make proper use of company assets and resources and just for legitimate business purposes.
The Company is committed to protect the confidential information of its customers and partners. The employees of the Company do not retain any right of ownership or privacy over all the information collected through, or stored on, the Electronic Information or other Systems, beyond the measure provided for or permitted by law.
Protection and Proper Use of Company Assets
All employees must protect the Company’s assets and ensure their efficient use. Their misappropriation, careless handling and waste have a direct impact on the efficiency and sustainability of the Company. All Company assets must be used only for lawful, proper and authorized business purposes. Any potential incident of fraud, theft, embezzlement or misuse should be reported immediately in order to be investigated.
Company assets must not be used for non-corporate activities and employees must not pursue or engage in business transactions other than those related to the Company during their paid employment with the Company.
Commissions
Transparent dealings with customers and suppliers are essential for stable, long-term relationships. All our prospective partners are provided with fair and equal opportunities. Decisions are based on objective criteria such as price and quality, as well as the reliability and integrity of a partner. Giving or receiving any illegal commissions, bribes or similar payments, of any type, is prohibited.
Compliance Procedures
It is necessary for all of us in the context of our work to ensure the immediate and consistent application of the provisions of the Code of Ethics and Conduct and to avoid violations. The Code of Ethics and Conduct is applied by all employees – partners and defines the internal control procedures in the event of its violation.
In order to ensure compliance with this Code of Ethics and Conduct, the Company requires from its employees to become aware of its provisions by contacting the relevant personnel office.