C
CORPORATE GOVERNANCE
OTE Group has adopted and applies across its functions and third party relations the UN Global Compact principles on human rights, labor standards, environment and anti-corruption.
In this context, we have established the Compliance Management System, under which we have developed our Compliance Program; one that promotes ethical behavior and integrity at all levels within OTE Group through the adoption of control mechanisms and international best practices.
The effective implementation of the Compliance Management System safeguards the reputation and corporate image of all Group companies, further consolidates their strong market position and strengthens relations of trust and transparency with our Customers, Suppliers, Partners, Employees and Shareholders. Ethical behavior, integrity and anti-corruption are a shared responsibility within our Group.
Michael Tsamaz , Chairman & CEO OTE Group
Aris Dimitriadis, Executive Director Compliance, Enterprise Risk Management & Insurance OTE Group
COMPLIANCE WITH THE LEGISLATION IN FORCE, THE CODE OF CONDUCT AND THE INTERNAL POLICIES IS OF GREAT IMPORTANCE TO OUR COMPANY.
Compliance with legislation in force, with the OTE Group Code of Conduct and the internal Policies is of great importance to us.
Ensuring Compliance is a priority for the Company's Board of Directors.
Compliance stands for a solid commitment to the principles of integrity, transparency, fairness, professionalism, team spirit, and of respect for the rules; principles which are essential to govern the operation of the Group.
To that end, the Management has adopted and implemented a Compliance Management System (CMS), regarding the compliance of all (employees 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 Group and its employees. In so doing, the benefit is for all: the Group per se, the employees, the customers and the suppliers of OTEGLOBE.
The effectiveness of the CMS relies on the commitment and the support of both management and employees.
The Company's CMS is reviewed by independent external auditors, who confirm the effectiveness of the procedures supporting it.
Key elements of the CMS
The prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the Group and its employees are protected from any legal consequences due to misconduct, while the reputational risks of the Group are reduced. Prevention is achieved mainly through:
- The employees' training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, 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 reporting any violations of Policies, regulations and of the legislation in force, the Company has established the relevant communication channels.
CMS Operation
For the implementation of the CMS at the OTE Group, Compliance Officers have been designated at the Group subsidiary companies.
Management of Human Rights issues
Furthermore, the Company has designated on a corporate level a responsible Officer for managing Human Rights issues, to whom, together with the designated persons in the group companies, internal and external inquiries as well as any relevant tip offs are addressed.
OTEGLOBE declares that it complies with the applicable laws and strives to comply with the international standards so as not to violate human rights and, to this end, it has adopted and applies the "Code of Human Rights & Social Principles", as binding on all Group companies.
In the context of implementation of the Compliance Management System, the following Policies and Codes are in force:
- OTE Group Code of Conduct
- OTE Group Policy on Avoiding Corruption and other Conflicts of Interest
- OTE Group Code of Ethics for Senior Financial Officers
- OTE Group Whistleblowing Policy
- Binding Corporate Rules Privacy
- OTE Group Policy on Ιnsider Τrading
- OTE Group Policy on Anti-Trust Law
- OTE Group Donation Policy
- OTE Group Sponsoring Policy
- OTE Group Policy on Accepting and Granting of Benefits
- OTE Group Anti-Fraud Policy
- OTE Group Event Policy
- Policy on Avoiding Sexual Harassment within OTE Group
- Policy on Employee Relations within OTE Group
- OTE Group Corporate Responsibility Policy
Incidents of Misconduct
You may report incidents regarding violations of company Policies, Procedures or applicable laws (e.g. fraud, corruption, theft, embezzlement, money laundering, falsifying accounting records and financial statements, non-compliance with the OTE Group Code of Conduct, or/and OTE Group Policies, issues relating to human rights and in general, any act or omission which could harm the Company or its reputation) by using the communication channels mentioned below:
- Via e-mail: whistleblowing@oteglobe.gr or tellmecompliance@oteglobe.gr
- Via telephone: +30 210 8762636 (Monday through Friday: 10am until 5pm)
- Via fax: +30 210 8762600
- Via mail: OTEGLOBE
Compliance Office 6-8 Agissilaou str., 151 23 Maroussi, Athens, Greece
Employees or third parties who provide information on wrongdoing or violations of corporate Policies, as well as employees or third parties mentioned or included in those tip-offs shall have the right to obtain access to the personal data, to obtain information as to whether or not personal data concerning him or her are being processed, shall have the right to object, to obtain rectification of inaccurate personal data, as well as to request at any time and without charge the erasure of personal data they have provided under the terms of the General Data Protection Regulation (EU 679/2016-GDPR).
OUR CODE OF CONDUCT (CoC) DEALS WITH THE QUESTION, "HOW DO WE WANT TO WORK?"
OTEGLOBE has developed an Enterprise Risk Management (ERM) System that supports Management in its strategic decisions, through the identification, evaluation, communication and management of enterprise risks.
In this context, the ERM System defines the strategy for monitoring, response and management of enterprise risks, in order to:
- Ensure that existing OTEGLOBE risks are systematically identified, analyzed and evaluated and that information relevant to risks and corresponding opportunities is promptly communicated to the competent decision-making bodies.
- Recording Company response to identified risks as well as to evaluate mitigating alternatives (such as transfer the risk to third parties, e.g. insurance companies).
- Establish tolerance limits (thresholds) for each level of risk assessment and evaluation. In case these limits are exceeded, relevant reporting takes place.
- Implement a common methodology across the OTE Group for the identification, evaluation and management of enterprise risks.
Methodology
Within OTEGLOBE, the Risk Assessment is a structured process for risk identification, analysis, evaluation and management of enterprise risks, in order to ensure better decision making by the company's competent bodies and that appropriate mitigation has been developed to address these risks and monitor the implementation of relevant measures.
In this context, a common Risk Assessment methodology is being applied to all risk assessments that are being performed by business units, with specific criteria for risk evaluation and assessment, in accordance with the requirements of the Standard ISO 31000 and based on the unified ERM OTE Group methodology.
RMS Operation
For the implementation of the ERM System, Risk Managers have been designated at the business units as well as at the Group subsidiary companies. The tasks of Risk Managers include the reporting and monitoring of the risks managed by their business units / subsidiary companies of the Group, in compliance with the OTE Group ERM methodology.
In the context of implementation of the Company’s Enterprise Risk Management System, the following Policy applies:
- OTE Group Enterprise Risk and Insurance Management Policy
This policy describes the current requirements for enterprise risk and insurance management of the OTE Group and the associated responsibilities.