Anti-Bribery & Anti-Corruption Policy

Vision and Purpose

The Management of ANTISEL A. SELIDIS BROS S.A. recognizes that bribery represents a significant threat not only to society as a whole but also to every organization in both the public and private sectors.

 

We have an obligation to our company, society, employees, business partners, and customers to operate with integrity across all of our activities and to communicate our expectations for reducing bribery risk.

 

ANTISEL recognizes bribery risks and has allocated all necessary resources to develop and implement a comprehensive Anti-Bribery Management System in accordance with the requirements of the international standard ISO 37001:2016 and applicable legislative requirements.

 

Within the framework of this system, procedures are documented and implemented to satisfy the requirements of the standard and legislation, appropriate for the operation of our company, while ensuring effective anti-bribery measures across all sectors and activities of the organization.

 

The company’s key objectives for preventing bribery are:

• Continuous compliance with all legal and regulatory requirements related to anti-bribery measures
• Zero tolerance for bribery and corrupt activities
• Establishment of anti-bribery targets and appropriate mechanisms for reviewing and achieving them
• Encouragement of reporting incidents in good faith based on reasonable suspicions, without fear of retaliation
• Continuous updating and encouragement of suppliers and partners on anti-bribery awareness
• Assessment of risks related to anti-bribery issues that may arise during the execution of the company’s activities
• Ensuring full compliance with the Anti-Bribery Management System in accordance with the requirements of the International Standard EN ISO 37001:2016 and pursuing its continuous improvement

Introduction

Bribery consists of requesting, accepting, offering, promising, or providing money or other undue and improper benefits from or to a company employee or public official to secure commercial or personal advantage.

 

Examples of payments and activities used in bribery include:

• Cash gifts or equivalent cash payments
• Personal favors and reciprocal benefits
• Illegal commissions
• Promises of additional business activities
• Expensive travel, accommodation, and participation in events with no professional content
• Individual or family expenses covered by someone else (prepaid cards or gift cards)
• A loan from a supplier that is never repaid
• A requirement from a public official to be paid in order for an action to be executed

Scope of Application

The Anti-Bribery Policy applies to ANTISEL’s management team, employees, and business partners. The personal commitment of all company executives and senior managers to promote a culture against bribery plays a strategic role in promoting a culture of lawfulness at all levels.

 

The rejection of any bribery and corruption practice is stated clearly and definitively, as well as the absolute commitment of company’s management to the principles of ethics and integrity.

 

This Anti-Bribery Policy also governs the establishment of relationships with any business partner intending to enter into a professional relationship with the company and the continuation of business activities with them. All people mentioned above must know and comply with this Anti-Bribery Policy and applicable regulations in performing their duties, to ensure that the company is not exposed to the risk of sanctions and serious damage to its reputation

Policy Framework

The offering or acceptance of any form of improper payment, improper benefit, or bribery has no place in the company. Bribery is explicitly prohibited by Greek legislation, specifically the Greek Penal Code. Both the above and other legislative acts as well as European and international instruments, such as the Convention of the Organization for Economic Cooperation and Development (OECD) on Combating Bribery, impose serious sanctions on companies and individuals who violate them, including substantial fines and, in the case of individuals, imprisonment.

Transactions with Government Officials

It is strictly prohibited to provide, offer, or promise any benefit to government officials, directly or indirectly. This policy also prohibits facilitation payments, small-value payments, and gifts to government officials for the purpose of inducing them to commit improper acts within their duties.

 

The following are considered government or state officials:

• Officials, employees, or representatives of any government, department, agency, office, authority, body, or public international organization. A public international organization is an organization established by states, governments, or other regional or supranational bodies. Such organizations include, for example, the UN, the Organization of American States (OAS), and the International Red Cross.
• Persons acting on behalf of the government
• Employees or entities that belong to or are controlled by the government
• Candidates for political office

Transactions with Private Entities and Individuals who are not Government Officials

Even in transactions where government officials are not involved, due diligence and care are required to ensure that ANTISEL’s personnel and consequently the company operate with absolute integrity.

 

Under no circumstances should any benefits, advantages, or items of value be offered to any person who is not permitted to receive them, or with any intention to influence in an improper manner any business decision.

Corporate Hospitality and Gifts

This policy does not prohibit reasonable, proper, and lawful hospitality (the offering or acceptance of such) to or from third parties, if its purpose is to enhance the company’s image, the presentation of its services, or the establishment or maintenance of related business relationships.

 

ANTISEL’s personnel are permitted to offer or receive gifts or hospitality at a reasonable, proportionate, justified level in accordance with this policy. Under the company’s code of ethics, gifts and corporate hospitality of symbolic value are characterized as insignificant.

Reporting and Complaints Submission

The procedure for submitting, managing, and investigating any report or complaint, including cases described in this policy, as well as the principles governing data analysis, any record keeping, personal data protection, and protection against retaliatory acts in response to a report or complaint, are described in detail in the company’s whistleblowing policy.

 

Reports related to bribery or corruption concerns may be submitted through the channels made available by the company in accordance with applicable internal procedures and policies.

Approval and Review of the Policy

The Anti-Bribery Policy is approved by the company’s Board of Directors and is posted in updated form on the company’s official website.

The Anti-Bribery Policy is reviewed and revised by the company as necessary in response to any changes in applicable law, the Anti-Bribery Management System, or the company’s practices, and generally whenever necessary. In such cases, the most current Policy will be posted each time.