CORRUPTION PREVENTION
PROFESSIONAL CONDUCT AND ETHICS MANUAL
INTRODUCTION
From the very beginning, our Company was created based on the principles of honesty, integrity and absolute transparency.
We sincerely believe that these are the principles that led us to success and grew our business and that they will continue to give us competitive advantage and new business opportunities, maintain the company’s reputation and preserve the trust we enjoy from our suppliers and our clients.
At SIOURAS SA we take corruption seriously and we are committed to preventing it from occurring at all levels of our company.
Senior management is supportive and devoted to this course and always tries to act as a strong and visible model, to be an example of ethical business behaviour for all employees.
From the first day of joining our organization, our moral values become clear to all our members and every employee is called to embrace them and never exclude.
Through regular training and information, all our members are familiar with the defining key points that should be followed by all company staff on issues of regulatory compliance, corruption and bribery.
At the same time, all employees are encouraged to report deviant behaviours without fear or guilt and have the assurance of management for full support. The company guarantees the anonymity of the complainant and ensures that no one will be allowed to threaten or retaliate the person who filed the complaint.
Any delinquent behaviour that exposes the company and may also have legal consequences is dealt promptly and with the required rigor.
CORRUPTION PREVENTION
- Our company expects all our business partners to share the same ethical values and to ensure that all their business behaviour is in line with our ethical principles.
No employee should be involved in passive or energetic bribes when discussing with a public sector representative, approve payments, gifts, entertainment in order to promote business purposes or gain an unfair advantage.
- His/her behaviour and words should in no case leave room for misinterpretation that he/she could be suggesting or implying bribe.
- Any request, direct or indirect, of a public servant or third-party for the purpose of obtaining payments, gifts, travel, personal facilities or other benefits should be reported to the administration immediately knowing that the company will report it to the proper authorities.
- The choice and the way of cooperation with our suppliers are regulated by the existing company rules for the purchase of products and services as well as for the consulting and professional services. The selection of intermediaries and suppliers is made by employees the company trusts for their judgment, ability and authority.
- It is strongly prohibited for any employee in SIOURAS SA company, in addition to normal trade and institutional relations, to give or promise money, goods or other benefits to any person, so that they perform or omit acts in violation of the obligations deriving from their position or the obligations of fidelity, causing damage to the company / organization to which they belong.
- Any personal/family relationship with a member of the public sector or with a representative of a company SIOURAS already has or tries to establish cooperation, should be notified to the administration immediately and in advance.
- All contracts must be drawn up and comply with specific SIOURAS specifications that ensure that the company’s commercial interests and anti-corruption commitments are protected
- The managers of the administrative/accounting departments in the context of the tasks assigned to them ensure that each transaction is legal, authorized and verifiable. It must be correctly and adequately registered, to enable the control of decision-making, approval and implementation.
- All necessary supporting documents must be included and thus allow, at any time, to check the characteristics and incentives of the transaction, as well as the identification of the person who authorizes, implements, registers and verifies.
- In case of control by the authorities, all employees are obliged to provide with absolute honesty and transparency all the information and assistance requested, in accordance with company regulations and state laws, so as to facilitate the authorities in their work.
PROFESIONAL CONDUCT AND ETHICS
- All employees must maintain the confidentiality of the information assigned to them by the company unless the disclosure is approved by management or required by law. Confidential information includes all non-public information, such as trade and policy issues, customer and supplier lists, innovative products, new markets, marketing plans, recipes and production processes, customer complaints or requests. The obligation to maintain the confidentiality of information is valid even after the termination of the employment relationship.
- All employees must protect the company’s assets and ensure their legal and efficient use. Assets and resources include all physical and intangible assets.
- The company fully and without discounts respects the employment contracts of all employees, working hours and annual leave and urges employees to be formal in turn. In case of control by the labour inspectorate, all employees must have at their disposal all the necessary documents, considered hours, employment contract, doctor’s file, and staff list.
- All employees must prove daily in practice that they adhere to the ethical principles and values of our company. The way they communicate with suppliers and customers, whether orally or in writing through letters and emails, should always be guided by the principles of respect and integrity and never expose or endanger the company and its activity.
- Collaboration and teamwork are the cornerstones of our company and all members of our team are considered family and are expected to behave accordingly. Verbal attacks or actions that could be considered offensive and diminish the value and dignity of colleagues are considered unacceptable and are not tolerated by management.
- The safety of employees in all areas of the factory and in the offices of the Administration is the absolute priority for our company. All employees are provided with the necessary safety equipment, are regularly trained for its proper use through seminars and exercises and are constantly checked for compliance with all safety rules.
- Cleanliness and hygiene in all areas is considered a given and non-negotiable so as to ensure the quality of our products and the health of our employees. All employees are provided with the necessary equipment, are regularly trained for its proper use through seminars and exercises and are constantly checked for compliance with all safety rules.
- There is a fully equipped infirmary in the production area which all employees can visit in case of need or to consult the Doctor who visits the company once a week according to a pre-arranged schedule. It is also possible for each employee to make an appointment with the Doctor after telephone communication.
- The management of the company is responsible for updating the rules that govern its operation, for the continuous training of employees with group seminars or individual programs but also for the continuous and thorough control of their observance.
Ethical Principles
- Integrity: Conduct business with honesty and transparency.
- Compliance: Adhere to all legal and regulatory requirements.
- Fairness: Ensure fair competition and avoid anti-competitive practices.
- Accountability: Accept responsibility for actions and decisions.
Prohibited Conduct
- Bribery & Corruption: No offering, soliciting, or accepting bribes. Comply with anti-corruption laws.
- Fraud & Financial Crimes: Prohibit tax evasion, money laundering, and embezzlement.
- Anti-Competitive Practices: Avoid price-fixing, market manipulation, or abuse of dominant position.
- Data Privacy & Protection: Safeguard sensitive information and comply with privacy laws.
- Harassment & Discrimination: Maintain a respectful workplace; avoid misconduct or bias.
Reporting Violations
Employees must report unethical behavior through secure channels without fear of retaliation. Investigations will be conducted with confidentiality and fairness.
Disciplinary Measures
Violations may result in corrective actions, up to and including termination or legal consequences.
Training & Awareness
Employees will receive periodic training on ethical standards to foster a culture of integrity.
SUMMARY
- We do not offer or accept bribes from anyone from Public or Private sector.
- We avoid offering or accepting gifts and if it is necessary, it must be done with extreme care
- We strongly encourage and expect from all employees to immediately report any deviant behaviour.
- We always comply with State Laws and Company Regulations.
- We invest in staff training and ensure continuous and strict control.
- We always behave in a way compatible with the values and ethics of our company.
- We expect from all our business partners to share our ethical values.
Volos, 2/7/2025
SIOURAS SA
HARRIS SIOURAS
GENERAL MANAGER
