CORPORATE GOVERNANCE

Compliance
Code of Conduct

Compliance

Compliance with the legislation in force, the Code of Conduct and the internal policies is of great importance to our Company.

Ensuring Compliance is a priority of the Company’s Board of Directors.
Compliance stands for a solid commitment to the principles of integrity, transparency, justice, professionalism, team spirit, and of respect to the rules, principles which are essential to govern the functions of the Company.

On this purpose, the Management has adopted and implemented a Compliance Management System (C.M.S.), regarding the compliance of all (personnel and Management) with the legislation in force, with the Code of Conduct and with internal Policies, aiming to avoid risks and other legal consequences for the Company and its personnel. In so doing, the benefit is for all: the Company per se, the employees, the customers, the suppliers and the shareholders.

The effectiveness of the Compliance Management System relies on the commitment and the support of all: Management and employees.
The key elements of the C.M.S. are:

  • the prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the company and its personnel are protected from any legal consequences due to misconduct, while the reputational risks of the company are reduced. Prevention is achieved mainly through:
  • The employee’s training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, the manipulation of financial statements, leakage of confidential business information, etc.
  • The channels that have been developed for the communication with employees, so that the latter can submit questions regarding the implementation of the Code of Conduct and the Policies, in case they are uncertain as to how they should handle issues that come up in their daily work.
  • the detection of compliance violations and the response to them. In order to provide the possibility of filing a tip – off regarding violations of Policies, regulations and of the legislation in force, the Company has established the Whistleblowing Policy and the relevant communication channels.

In the context of this Policy, employees may nominally or namelessly report to OTEGLOBE Compliance Office a tip – off or express a concern or a complaint regarding potential violations of the Company’s Policies or the legislation. OTEGLOBE does not allow for any retaliation act on behalf of the management or other bodies of the Company, directly or indirectly against any person, who on good will, reports or expresses concern or complaint with regards to violation of policies or law.

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