A’ Industrial Area of Volos
Incident/Complaint Management Policy
SIOURAS S.A. (the company), within the framework of business ethics, seeks to operate in a transparent business environment.
In compliance with Law 4990/2022 (“Protection of persons reporting breaches of Union law”), the company operates with complete confidentiality and has a system in place for submitting incidents reports/complaints. This vital tool aims to reduce risks, identify and prevent improper practices, deter unethical behavior, and maintain trust in the company’s activities, allowing us to act promptly in cases of misconduct.
The purpose of this complaint management policy is to protect the company’s reputation, contribute to the disclosure of violations that harm the interests of a business, clarify the scope, operation, and investigation process for complaints, encourage interested parties to express any serious concerns in a timely manner and without reserve, and strengthen the trust of customers, suppliers, partners, and the company’s human resources.
The company has appointed an Incident Receipt and Monitoring Officer (IRMO) and ensures that the receipt of the complaint/incident report is confirmed to the complainant within seven (7) working days of receipt and that the complainant is informed of the actions taken within a reasonable period of time, which shall not exceed three (3) months from the date of acknowledgment of receipt.
- When should a incident report/complaint be made
The incident reporting/complaint system can be used to alert us of serious risks affecting individuals, our company, society, or the environment.
The incident reporting/complaint system can be used to report serious misconduct or unethical acts or suspicions relating to any of the following
issues:
- Violations of laws and regulations regarding accounting, auditing, banking and financial crime, or anti-bribery laws, such as misuse of company or customer assets;
- Breaches of public procurement contracts, Union competition rules, and acts that violate corporate tax rules,
- Violations in the areas of privacy and personal data protection, as well as network and information system security,
- Serious violations relating to the vital interests of the company or its network or the life or health of individuals, including risks to the public or the protection of personal data, such as serious environmental crimes or non-compliance with health and safety rules,
- Violation of company policy on combating discrimination, violence, and harassment in the workplace, especially serious forms of discrimination or harassment, such as verbal or physical disrespect toward an individual because of their background, religion, sexual orientation, particular situation, or other factors.
- Violation of anti-bribery rules, company ethics, any of the company’s policies, or laws and regulations applicable to our company or company personnel.
- Acts that may constitute fraud or corruption,
- Violations of applicable anti-money laundering legislation, such as non-compliance with our customer due diligence measures or reporting obligations
This list is indicative and includes the type and categories of matters of concern.
that fall within the scope of this policy.
- Which persons making complaints are protected by Law?
- Employees, whether full-time or part-time, permanent or seasonal, non-salaried, self-employed or consultants, or teleworkers,
- shareholders and persons belonging to the administrative, managerial or
- supervisory body, including non-executive members,
- volunteers and trainees, either paid or unpaid,
- employees of contractors, subcontractors and suppliers,
- former employees (including pensioners)
- prospective employees.
- third parties, legal or natural persons, who are connected with the complainants and may suffer retaliation in the workplace (e.g., colleagues or relatives of complainants).
The person making the complaint does not need to have a high degree of certainty.
or proof. It is sufficient to express a sincere suspicion, provided that there are reasonable grounds to believe that the complaint is necessary to reveal the violation, which is believed to be true.
The complainant may act anonymously or under their own name:
The complainant may submit a complaint electronically, stating their name and address, via email to siourasv@otenet.gr. The complainant may attach a file to the message. Complaints can be made both in English and Greek.
If the complainant does not wish to submit a message under their name, they have the option of submitting the complaint anonymously, and their anonymity shall be guaranteed throughout the entire process.
The company encourages the submission of incident reports/complaints and guarantees that all messages received shall be treated confidentially. The company commits to keeping the identity of the complainant confidential throughout the entire process, unless disclosure is deemed necessary for the effective investigation of the case (e.g. in the context of any judicial or legal proceedings).
The complainant is encouraged to share any information which is known to them (such as sufficient details about the incident and the person or persons involved or present as well as documentation which could effectively verify the validity of the reported incident), in order to facilitate the investigation.
The company is committed to protect from retaliation, the persons who report in
good faith, without abusing the incident reporting/complaint management system.
However, it should be noted that the deliberate reporting of false or
misleading information is strictly prohibited. Abuse of the incident reporting/complaint system,
may lead to measures being taken against the person who committed the abuse, as well
as criminal penalties, in accordance with the provisions of Law 4990/2022.
- The investigation process
- The Incident Report/Complaint Management Team
To manage reports, the company has set up a management team consisting of three members of Management, one of whom is the Incident Receipt and Monitoring Officer (IRMO). All members of the team act with full
confidentiality and integrity.
The members of the aforementioned team have signed a confidentiality agreement, particularly with regard to the information they receive as members of the incident report/complaint management team. Lawyers or other experts may be involved in the investigation process, provided they have signed a confidentiality agreement. If necessary, the case may also be referred or assigned to specific persons within the company.
To ensure the objectivity and integrity of the process, if the person referred to in the complaint is a member of the complaint management team, this conflict shall be immediately reported and the person referred to in the incident report/complaint shall be removed from the list of recipients (management team for the specific complaint) and shall not be involved in the investigation of the case.
- Submission of an incident report/complaint – Receipt of message
The incident report/complaint should be sent to siourasv@otenet.gr.
When an incident report/complaint is received, the incident report/complaint management team makes a decision as to whether to accept or reject the message.
The management team may reject a message and terminate the process by archiving the complaint if one or more of the following criteria apply:
- the alleged conduct does not constitute reportable conduct under the Law or this policy, nor does it constitute a violation falling within the scope of this policy, or there is no serious evidence of such a violation;
- the message has not been made in good faith or is malicious,
- the complaint is unintelligible or submitted in an abusive manner,
- there is insufficient information for further investigation,
- the issue of the incident report/complaint, has already been resolved
If the incident report/complaint does not fall within the scope of this policy, the management team shall take appropriate action to resolve the issue, e.g., assigning the case to the appropriate person or team. Cases related to complaints deemed unfounded
or in bad faith shall be archived without further action. In any case, the incident management team shall send a message to the complainant to inform them that their complaint has been archived and the reason for this. If the complainant deems that their complaint has not been dealt with effectively, they may submit a report to the National Transparency Authority (E.A.D.).
If the message is accepted, appropriate steps shall be taken to investigate as follows.
- Investigation
All incident reports/complaints are handled in accordance with this policy, objectively, seriously, and confidentially, taking into account the interests of all parties involved.
Only members of the management team are given access to complaints that have been submitted, using unique codes.
In the case of an anonymous complaint, no one from the management team shall attempt to reveal the identity of the complainant. However, even in the case of a non-anonymous complaint, the identity of the complainant shall remain confidential.
The management team shall investigate the incident report/complaint and, if necessary, may ask additional questions. It then decides on whether and how an incident report/complaint should be delegated.
- Protection of the complainant in cases where the complaint is made non-anonymously
In accordance with this policy, anyone who expresses, in good faith, genuine suspicion or doubt about the issues referred to in this policy is protected from any retaliation arising from the fact that they have submitted an incident report/complaint. The complainant, even if they were wrong, is entitled to protection if, at the time of reporting, they had reasonable grounds to believe that the information relating to the reported violations was true.
The identity of the complainant shall be treated with absolute confidentiality and shall not be disclosed except in exceptional circumstances, such as if the complainant consents, or if the complainant acts in bad faith and makes a malicious, false or unsubstantiated statement, or if this is required by any subsequent legal proceedings, for instance as required by EU or national law, in the context of investigations by competent authorities or in the context of legal proceedings, and to the extent necessary to serve the purposes of this Policy or to ensure the legal rights of the alleged perpetrator.
In particular, in cases of civil or criminal offences, the complainant shall be informed in advance that his or her identity and other confidential information may have to be disclosed to the judicial authorities in the course of court proceedings, unless such disclosure would undermine the investigation or court proceedings.
As governed by confidentiality for those who have been the subject of complaints or who are mentioned in complaints, and any other confidentiality issues, the complainant shall be informed of the outcome of the investigation.
- Protection of a person referred to in a complaint
The identity of the person against whom an allegation has been made shall be protected and kept confidential throughout the investigation of the complaint, in order to avoid any risk of stigmatization and victimization.
Provided that this does not hinder the investigation, the alleged offender shall be informed and given the opportunity to respond to the complaint.
The rights of individuals identified in an incident report are provided for in the relevant legislation on the protection of personal data.
- Submission of external reports
The complainant has the option of submitting an external incident report/complaint directly to the National Transparency Authority (E.A.D.).
This complaint shall be submitted in writing or via an electronic platform accessible also to persons with disabilities, and in particular:
- Electronically: via email to kataggelies@aead.gr or by completing the appropriate complaint form: https://aead.gr/submit-complaint/
- By post: Mail to the postal address of E.A.D.: 195 Lenorman & Amfiarou Streets, Post Code 104 42, Athens
- In person (or through a legally authorized representative) by submitting the complaint to the offices of E.A.D.: 195 Lenorman & Amfiarou Streets, Post Code 104 42, Athens.
If you have any questions or require further information regarding your rights and how to exercise them, please contact us at the following email address: siourasv@otenet.gr or at the following postal address: SIOURAS SA, A’ INDUSTRIAL AREA OF VOLOS 38500 VOLOS. To the attention of the official responsible for receiving and managing reports.
If you require any clarification regarding the incident report/complaint management process, the types of misconduct that may be reported under the complaint management system, or any other query, please contact the complaint management team at the following email address: siourasv@otenet.gr
