ANTI-BRIBERY POLICY

KALLIERGOS O.T.M. S.A. recognizes the need to combat corruption and bribery to enhance the Company's credibility and reputation, ensure transparency and efficiency in its business operations, and meet the needs and expectations of its stakeholders. To this end, the Company has developed, implemented, and committed to maintaining and continuously improving an Anti-Bribery Management System in accordance with the requirements of the International Standard for Anti-Bribery Management, EN ISO 37001:2016.

Scope of the System:

  • Preparation of Structural Studies
  • Provision of Technical Consultancy and Supervision

Through this initiative, the Company aims to reinforce Management's commitment to zero tolerance for bribery and to raise awareness among all employees and partners about combating bribery. This is achieved by creating procedures that ensure the prevention, deterrence, and effective response to bribery.

KALLIERGOS O.T.M. S.A. is particularly committed to:

  • Complying with the applicable legal and regulatory framework for combating bribery.
  • Meeting the requirements of the Anti-Bribery Management System in line with ISO 37001:2016.
  • Encouraging confidential reporting of incidents, or suspected or attempted bribery, through specific communication channels, without fear of retaliation, to the Anti-Bribery Compliance Function Manager (ACFO) and relevant Company personnel.
  • Clarifying the authority and independence of the Compliance Function Manager in the Company's regulatory compliance and anti-bribery audit processes.
  • Explaining the consequences of non-compliance with this policy.
  • Supporting the independence and operation of the Compliance Function Manager in the Company’s anti-bribery compliance audit process.
  • Providing the necessary resources and appropriate tools to train, raise awareness, and engage staff on compliance and anti-bribery issues, with the aim of continuously improving the system.

Continuous Improvement of the Anti-Bribery Management System
The Company ensures ongoing enhancement of its Anti-Bribery Management System through the following tools:

  • Risk assessment and implementation of necessary actions.
  • Establishing and achieving regulatory and anti-bribery compliance objectives.
  • Implementing due diligence and anti-bribery controls.
  • Conducting internal reviews.
  • Providing staff training and raising awareness.
  • Managing non-compliances and implementing corrective actions.
  • Conducting periodic reviews by Management and the Compliance Function Manager.

The relevant requirements of stakeholders, including obligations to comply with both the applicable legal framework and anti-bribery legislation, as well as their involvement in the Anti-Bribery Management System, have been integrated into the Company's operations through its system documentation.

In this context, the Firm's Management is committed to supporting the implementation, monitoring, and maintenance of the Anti-Bribery Management System, which will be periodically reviewed, revised, and improved as needed to ensure continuous regulatory compliance with both the legal and anti-bribery frameworks.

Executives, employees, and third parties working on behalf of KALLIERGOS O.T.M. S.A. are strictly prohibited from offering, promising, or giving a bribe, as well as from soliciting or accepting a bribe. This policy is binding on Management, officers, employees, and all others involved in the Company's operations, including external providers and professional partners of any kind.

Non-compliance with this policy, whether intentional or unintentional, may result in disciplinary action and criminal prosecution in accordance with applicable anti-corruption laws.

This Anti-Bribery Policy is communicated to all interested parties, is publicly available, and is periodically reviewed by the Company's Management.

Athens 02 September 2024

The Chairman of the Board & Managing Director

Panagiotis Plainis