ISO 37001: Anti-bribery policy
The Organization’s Top Management hereby affirms its commitment to the establishment, implementation, maintenance, and continual improvement of the Anti-Bribery Management System in accordance with the requirements of the international standard ISO 37001:2016.
Top Management upholds the highest standards of ethical conduct and mandates that all employees, business partners, contractors, and any other stakeholders with whom the Organization engages shall comply fully and without exception with the present Policy.
All employees, including members of Management, have received appropriate training regarding the implementation and obligations of this Policy.
The Organization adopts a zero-tolerance stance toward bribery, corruption, facilitation payments, or any other unlawful act. It adheres to all statutory procedures concerning disciplinary measures and sanctions applicable to personnel who violate this Policy.
The Organization permits solely the acceptance or offering of official ceremonial gifts not exceeding a value of €50, in alignment with the provisions applicable to the Greek public sector, and only where such gestures are reasonable, customary, and proportionate to the nature of the relationship. Gifts shall be avoided where their acceptance could reasonably be perceived as influencing, or having the potential to influence, decision-making processes.
The Organization shall not engage, collaborate, or maintain any form of relationship with entities involved in corrupt practices, and will immediately terminate any such association, should evidence of such practices arise. Management and employees comply with all applicable national and European Union laws governing bribery and corruption.
In jurisdictions where legal or other applicable requirements diverge from this Policy, in some countries, Top Management shall determine the due diligence measures to be undertaken prior to entering into any contractual or cooperative relationship. Under no circumstances shall the Organization engage in the offering, solicitation, or acceptance of a bribe.
The Organization shall not knowingly participate in any transaction or commercial arrangement that involves corrupt practices. Business partners, contractors, and other third parties representing the Organization shall be contractually required to adhere to this Policy.
All payments, fees, expenses, and related financial transactions must be lawful, reasonable, legitimate, and supported by appropriate documentation.
Conflicts of interest are strictly prohibited. As a condition of employment, Management and employees are forbidden from undertaking private business, political, or charitable activities within the Organization, that may give rise to a conflict of interest. Such activities may only be undertaken with prior written authorization from Top Management, granted solely where no conflict of interest exists.
Furthermore, all contractors and third parties are contractually obliged to disclose to the Organization—prior to commencing any form of representation—any actual or potential conflict of interest relating to relevant stakeholders. The Organization does not make, authorize, or participate in any political or party-related donations.
Charitable donations may be made only with the prior written approval of Top Management.
Management, employees, and contractors shall utilize the Organization’s confidential reporting channels to raise concerns or submit allegations. All members of Management are trained and obligated to properly handle reported concerns. Failure to report, escalate, or investigate such concerns constitutes a serious disciplinary offense and may also give rise to criminal liability. Retaliation of any kind against individuals who submit reports or concerns in good faith is strictly prohibited.
Any employee or other party who observes conduct that may constitute a violation of this Policy, or who is approached by any individual for the purpose of bribery or corruption, is strongly encouraged to contact the Anti-Bribery Management System Officer immediately at 2164007700 or via email at peny.papadopoulou@ect.com.gr.
The Organization shall treat all reports confidentially, to the extent permitted by law. Anonymous reporting is allowed, at the request of the reporting individual.
The Anti-Bribery Management System implemented in accordance with ISO 37001:2016 serves to prevent the Organization’s involvement in any corrupt activity and to support the evaluation, escalation, and reporting of matters requiring further investigation or action. This System is fully endorsed and supported by Senior Management.
The General Manager receives regular updates on all matters relating to the Anti-Bribery Management System. This Policy, along with all supporting Procedures, is reviewed at least annually. Top Management remains committed to ensuring the effective operation of the Anti-Bribery Management System and to achieving its objectives for the adequate mitigation of bribery risks across the Organization.
The Compliance and Bribery Investigation Committee is responsible for responding to queries and clarifying any issues related to bribery or corruption involving personnel. The Committee facilitates the resolution of all matters arising from such communications.
This Policy is communicated both internally and externally, ensuring that all employees, partners, and stakeholders are informed of the Organization’s commitment to combating bribery and corruption.
ATHENS, 3 August 2025
GENERAL MANAGER: MICHAEL RIZOPOULOS