ECONOMY

1) The practical application of our Management Approach against corruption and bribery involves:

- The analysis of the prevailing conditions and the identification of potential risks or threats which may encourage the occurrence of non-ethical incidents in our corporate environment. These are implemented through annual self-assessments and internal preventive audits with a view to introducing measures to combat corruption at the level of the Group’s subsidiaries.
- Ensuring that all transactions carried out on behalf of the Group by our shareholders, employees, subsidiaries and key business partners and suppliers, are characterised by a high level of integrity and by high moral standards. Through established procedures, applying primarily in our Purchases and Procurement Units for the selection of suppliers and other business partners, we check the conditions under which every single transaction is carried out, in order to identify and eliminate those which may give rise to incidents of corruption.
- Our operation as a “Responsible Corporate Citizen”, reflected in a number of voluntary initiatives such as: adherence to market rules, participation in international standards to strengthen transparency, establishing transparency as an important item on the agenda of the ongoing dialogue with our key Stakeholder groups, the provision of training on anti-corruption policies and procedures to our employees of all levels and in general in our dedication to ethical business practices and proper corporate governance.

2) In each one of our subsidiaries, we implemented a self-assessment procedure regarding our performance in connection with actions to combat Corruption and Bribery, drawing on the guidelines accompanying the relevant tool of Transparency International.

3) Through the procedures applied in the Purchases – Procurement Units of our subsidiaries, we checked the selection of business partners as well as all types of transactions.

4) Through the Internal Audit System, we assessed the relevant risks and verified the compliance of our subsidiaries' operations with our established policies and procedures, as these are defined in our Code of Professional Ethics, in the Internal Regulation of each individual company, and in the laws and regulatory provisions in force.

5) We upgraded our UNGC COP Differentiation Level from Active to Advanced. In doing so, we strengthen our commitment to Principle 10 of the UN Global Compact and we move towards the gradual application of specific best practices that will help us implement our policy more effectively.