BUSINESS: 381 PRACTICES
ELLAKTOR Group is active in the segment of Concessions, Environment and Real Estate Development - Management. With a presence in 4 countries and 2,300 employees, the Group operates with environmental and social responsibility, providing high-quality infrastructure projects, which aim to promote sustainability and the continuous creation of added value for the entire Greek economy and society.
The Company's actions related to dealing with corruption concern all the principles and practices the Company adopts, to ensure its performance, the interests of its shareholders and its stakeholders. Any incident of non-compliance with the principles and policies of the Company endangers the good reputation, reliability, trust of the social partners and, by extension, its financial results. Therefore, the principles of corporate governance form the basis of the Group's governance system, through which the proper and effective management of the Group is achieved with the efficient use of all available resources, as well as transparency in corporate operations for the long-term common interest.
It is addressed to the members of the Board of Directors and the employees who exercise managerial duties in the Group companies, the human resources, and the business partners of the Group.
Since the adoption of the above-mentioned Integrity Program (2020 - 2021) until today, the Group has been systematically taking actions to improve it, and at the same time applying the appropriate technical and organizational measures, to carry out its operations in full compliance with the applicable legislative framework to combat corruption, and always in accordance with the imperatives of the principles of integrity and transparency.
ELLAKTOR Group has established and implements a Compliance Management System that refers to the compliance of both Management and human resources with the applicable legislation and regulatory framework, the Code of Ethics and the Policies and Procedures of Compliance Function, with the aim of avoiding risks and other legal consequences for the Group and the employees. The Compliance Management System has been certified according to ISO Standard 37301:2021-Compliance Management Systems, by an independent certification body, in terms of compliance with the requirements of the standard and the effectiveness of the procedures applied. Furthermore, in order to successfully implement the System, the Group has developed a relevant Integrity Compliance Program which includes a series of Integrity Compliance Measures (ICMs) with the aim of ensuring our compliance with the applicable legislation and regulatory framework, and consequently the correctness of our relevant decisions and actions.
The Group's actions related to dealing with corruption in all its forms, and particularly, the development of the Integrity Compliance Program, are based both on the creation of regulatory documents that govern all its operations and constitute the Integrity Compliance Measures, i.e. of the Rules of Operation, the Codes, the Policies and Procedures, as well as in carrying out scheduled compliance audits.
The Integrity Compliance Program includes all the necessary tools and resources to promote an integrity mindset and follows the approach: "Commit - Assess - Act - Monitor: Always Improve".
Integrity and transparency are ensured both by the parallel and complementary application - as well as by the systematic and effective control of the implementation - of the following Regulation, Codes, Policies and Procedures:
I. Rules of Operation: It incorporates the principles of Corporate Governance adopted by ELLAKTOR Group and is harmonized with its corporate profile, corporate purpose, structure, organizational chart, as well as its internal Policies and Procedures.
II. Code of Ethics: The Code includes the fundamental principles, rules and values that form the framework of the Group's corporate activities, which in turn determine our daily behavior and define the standards, ethical values, and expectations that the Group has from its employees, as well as from third parties that interact with the latter.
III. Business Partner’s Code of Conduct: The Code defines the standards of integrity expected from all ELLAKTOR Group partners and is fully harmonized with the Code of Ethics.
IV. Organizational Governance System: In October 2022, after a relevant inspection by an independent body, ELLAKTOR received the ISO 37000:2021 Governance of organizations certificate and is one of the first companies in Greece to receive the relevant Attestation. ISO 37000:2021 Governance of organizations incorporates all international good practices and is the global benchmark for good governance. Good governance not only fosters an environment of trust, transparency, and accountability, but also helps align an organization's purpose with the needs of society, building strong relationships with stakeholders while effectively managing and conserving its resources.
V. Anti-Bribery Policy: ELLAKTOR Group is committed to zero tolerance for bribery and corruption, complies with all applicable anti-corruption legislation, and conducts its business activities with absolute transparency. It is worth mentioning that the Group implements an Anti-Bribery Management System, certified in 2020, according to the ISO 37001:2016 standard, as well as that among the important subsidiaries of the ELLAKTOR Group, the company HELECTOR, implements an Anti-Bribery Management System, according to ISO 37001:2016, certified since 2017, the equivalent of AKTOR CONCESSIONS since 2020, and that of REDS since 2021.
VI. Conflicts of Interest Policy and Procedure: Which are applied together with the other applicable Policies and Procedures, as well as the Code of Ethics. These regulatory documents define the necessary procedures for taking preventive measures, as well as measures to manage cases of conflict of interest.
VII. Whistleblowing Policy and Procedure: The Group ensures the implementation and management of an effective complaint management system, in accordance with international standards and implements a Whistleblowing Management System certified according to the ISO 37002:2021 standard, creating a framework of obligations and guidelines, in order for it to be used as a tool to prevent, deter and fight corruption in general.
VIII. Third Party Due Diligence Policy: ELLAKTOR Group is committed to applying high standards of integrity in all its business functions and activities and has set the audit framework and criteria regarding the establishment, continuity, and monitoring of relationships with Third Parties, in order to ensure that they meet the integrity standards and ESG (Environmental, Social and Governance) criteria set by the Group. This Policy enables both monitoring of integrity risks originating from Third Parties, as well as inspection and assessment of their compliance with laws, regulations, Group standards and values, ESG objectives and other rules. It is also worth noting that the relevant evaluation of Third Parties can apply with ease by using the platform Compliance Catalyst (Bureau Van Dijk, Moody's Analytics Company).
Such regulatory documents, which are available on the Group's official website, are applied without exception by its subsidiaries and are recommended for adoption by the Group's partners in case they do not have relevant policies and procedures.
In addition, the Group's Compliance DIvision systematically implements actions for the continuous information and training of all the Group's human resources, regarding the requirements of the regulatory framework and the importance of complying with them, but also with the aim of raising employees' awareness of integrity issues, corruption, submission, and management of reports. In accordance with the relevant Whistleblowing Policy and Procedure applied by the Group - namely through the specially configured reporting application "Talk2ELLAKTOR" - the submission of reports for incidents of all kinds of irregularities, omissions, or punishable actions can take place with ease and under complete protection.
With their integration into the corporate culture over several years, the fundamental principles, rules and values that promote integrity and transparency form the basis of the modern governance system of ELLAKTOR Group. As a result of this fact good and efficient management and transparency in all corporate operations is achieved, aiming at the long-term interest of all stakeholders, as well as at the long-term sustainable development, based on trust, honesty, and continuous dialogue.
The headquarters of the Group, i.e. the ELLAKTOR Company as well as its subsidiary companies, including those based abroad.
In the context of actions to promote integrity and transparency in all matters related to its business operation, ELLAKTOR Group openly declares its commitment to operate with transparency and corporate ethics, adopting specific good governance policies and practices, participating since 2021:
i. in the “Association of Certified Fraud Examiners (ACFE) Corporate Alliance” Program, to combat fraud, as well as
ii. in the "Business Integrity Forum (BIF)" of Transparency International - Greece.
In addition, the Group, in the context and for the needs of the above-mentioned audits and certifications, has cooperated with an independent Inspection and Certification body, and specifically with "Swiss Approval International".
The Group's anti-corruption actions bind all its executives and employees. For this reason, high importance is given to the systematic education and training of the Group's human resources, especially in matters of integrity, corruption, but also on the procedures for submitting and managing reports. In particular, the relevant training is carried out based on defined training programs, both through an online training platform (e-learning), available to all Group's employees, as well as in person in the form of training seminars. In this way, employees' awareness of integrity issues, such as the Code of Ethics and the rules governing the operation of the Group, is strengthened, while the importance of adopting preventive measures and mechanisms to enhance transparency and integrity in all activities of the Group is highlighted, as well as intensifying the relevant control mechanisms. In addition, it should be noted that in the process of recruiting new staff, there is a notification, a declaration of receipt and acceptance of the Code of Ethics, so that, in any case, new employees in the Group are informed of its zero tolerance regarding any incident that constitutes a deviation from the Integrity Program. Furthermore, with the implementation of the relevant Whistleblowing Policy and Procedure - namely through the reporting application "Talk2ELLAKTOR" - all employees are given the opportunity to raise concerns and also to report incidents of all kinds of irregularities, omissions or punishable actions. In the context of the said procedure, in accordance with the relevant legislation, and to encourage employees to submit the relevant reports, the Group ensures the confidentiality of the information and the absolute protection of the complainants from "retaliation".
In the context of actions to promote integrity and transparency in all matters related to the business operation of ELLAKTOR Group, and in combination with the corporate governance model it applies, the following are achieved:
• the elimination of irregularities and cases of corruption
• the best and most effective risk monitoring and management
• the implementation of an effective Internal Control System
• the strengthening of the reputation of the Group
• the strengthening of the confidence of the investing public
