HELLENiQ ENERGY

The initiative concerns the creation and implementation of a comprehensive and modern regulatory compliance framework that enhances transparency, accountability and integrity across all levels of HELLENiQ ENERGY's Group operations in Greece and abroad.

At HELLENiQ ENERGY, our success is measured not only by our business performance, but also by the way we choose to operate: with transparency, integrity and accountability. These principles are not just guidelines—they are the core of our culture, the foundation on which we build the trust of our colleagues, partners and society.  This is how we ensure sustainability and create growth for all.

That is why compliance with laws, regulations and our internal policies, ethical business practices and corporate responsibility are not just a formality. It is a collective commitment that ensures our working environment remains fair, safe and beneficial to all.

Guided by this commitment,  
✅We have incorporated the most up-to-date principles of compliance and business ethics, ensuring that we respond to today's challenges and regulatory changes.
✅ We have created new reporting channels for the timely and secure recording of concerns or violations through a whistleblowing policy that preserves the anonymity and provides protection of those who report.
✅ We have made our rules and principles even clearer, so that every decision we make is the right one and reflects our values.
✅ We have invested in new technologies that ensure more effective compliance.

More specifically, this framework includes:

• An updated Code of Conduct that serves as a guide to behaviour and ethics.
• A Reporting Policy and a new whistleblowing platform, which enhance transparency and enable the safe reporting of incidents.
• Regulatory Compliance Manager, an innovative platform that will bring together all relevant legislation, policies and regulatory obligations, creating for the first time a single point of truth for the legality and proper functioning of the Group, with Regulatory Compliance as its guardian.
• Training programme (e-training and in-person) for all staff, so that the principles become common knowledge.
• Creation of new policies and procedures to comply with the current regulatory framework, such as: AI Act, Accessibility Act, Sanctions Policy, Know Your Customer (KYC).

In addition, due diligence procedures have been incorporated to assess existing practices, risk assessements, and the appointment of responsible persons for the implementation and monitoring of policies. At the same time, all personal data protection policies are systematically updated.

At the digital level, a Regulatory Compliance page has been created on the intranet, with posted policies, tools and training material, as well as a special section on the corporate site, so that external stakeholders can also access it.

• All HELLENiQ ENERGY Group staff (covering all levels and specialisations).
• Executives and management.
• Partners, suppliers and contractors.
• Regulatory and supervisory authorities.
• Shareholders and the investment community.

Start: January 2025
Completion: January 2026 (full operation).
The programme will then continue to evolve as the systems are tested and optimised.

The regulatory compliance and governance framework has been developed based on international guidelines and standards and includes multiple dimensions:

1. Code of Conduct

• New version (2024), fully updated, harmonised with international practices.
• Covers issues such as human rights, equal opportunities, zero tolerance for violence and harassment, responsible communication and use of social networks, as well as a commitment to environmental protection.
• Creation of a special platform with the option of submitting anonymous or named complaints.

2. Reporting Policy & Whistleblowing Platform

• Policy that strengthens the protection of whistleblowers.
• Creation of a special platform with the option of submitting anonymous or named complaints.
• Ensuring absolute confidentiality and discretion.

3. Regulatory Compliance Manager

• An innovative digital platform that brings together the entire regulatory framework. This platform was designed by the Group to meet its specifications, needs and requirements.
• It allows relevant employees and executives to have real-time access to the Group's legislation, policies and regulations.
• It ensures continuous updating and full traceability.
• It makes the relevant employees responsible for the proper functioning of the departments and Regulatory Compliance a point of reference and the ultimate "guardian" of proper functioning.

4. New Policies and Regulations

• Creation of a framework for the implementation of new legislation such as the AI Act and Accessibility Act, with due diligence, risk assessment, drafting of new policies and appointment of persons responsible for implementation.
• Development and implementation of Sanctions Policy and Know Your Customer Policy.
• Systematic updating of policies for the protection of personal data (GDPR).

A total of 18 policies were revised and/or created.

5. Training

• Creation of e-learning modules with examples and scenarios.
• Organisation of live seminars and workshops.
• Coverage of all staff, regardless of position or location.
• Objective: to establish a culture of compliance at all levels.

A total of 434 people were trained.

6. Digital Transformation

• Creation of a Regulatory Compliance page on the Group's intranet with content including: Code of Conduct, Reporting Policy, Reporting Platform, other policies related to Regulatory Compliance, Training & other material, Latest news on Regulatory Compliance.
• Posting of policies and reporting platform on the corporate site, accessible to all.

The framework was developed in collaboration with specialised legal and regulatory advisors, as well as using international standards (UN Global Compact, OECD Guidelines, GRI Standards).

The success of the framework is based on the active participation of all employees.

• They participate in e-learning training courses and face-to-face programmes.
• They stay informed through the Compliance page.
• They contribute to the implementation of policies in their daily work.
• They collaborate in interdisciplinary teams (Environment, IT, Legal Service, Regulatory Compliance, DPO) to implement and improve the new framework. 

HELLENiQ ENERGY Group – implementation in all facilities and subsidiaries in Greece and abroad, while respecting local specificities.

• Establishment and distribution of the new Code of Conduct (2024).
• Operation of the revised Reporting Policy and whistleblowing platform.
• Development and operation of the Regulatory Compliance Manager platform as a central compliance database.
• Training of 434 employees through e-training and seminars.
• Creation and/or revision of 18 policies (AI Act, Accessibility Act, Sanctions, KYC, GDPR).
• Enhancement of transparency and trust in the Group.
• Leveraging technology to modernise and more effectively implement regulatory compliance.

• Protection against regulatory and operational risks.
• Creation of a culture of integrity, responsibility and ethics.
• Improvement of corporate reputation and strengthening of stakeholder trust.
• Reduction of the risk of penalties and fines.
• Upgrading corporate governance in the energy sector.
• Strategic alignment with ESG reporting standards and Sustainable Development Goals.