Compliance with legislation in force, with the Code of Conduct and the internal Policies is of great importance to OTE Group.
To that end, OTE Group has adopted and implements an Anti-Corruption Management System, regarding the compliance of all (employees and management) with the above-mentioned.
This System is reviewed by independent external auditors, who confirm the effectiveness of the procedures supporting it.
The System is certified in accordance with the international standard ISO 37001:2016 (Anti-Bribery Management Systems), by the independent Certification body “TUV Hellas (TUV Nord) S.A.”.
The prevention of misconduct in parallel with compliance with the relevant OTE Group policies (Code of Conduct, Policy on Avoiding Corruption and other Conflicts of Interest, Policy on Accepting and Granting of Benefits, Donation Policy, Sponsoring Policy, Anti-Fraud Policy, Supplier Code of Conduct) are the System’s key elements. Prevention is achieved mainly through:
the employees’ training on anti-corruption and as well as their awareness, and
the selection of our business partners, following integrity checks by use of public sources as well as their commitment to adhering to our principles.
A] As far as the employees’ training is concerned, it is carried out at specific stages of the employee’s career in the company, in accordance with their level of hierarchy and duties, following a relevant risk assessment.
The training methods derive from the number of employees to be trained, their level of hierarchy and their duties, and are the following:
classroom trainings (newly hired, persons promoted to managerial positions, Members of the Upper Management and BoD, employees from certain business units who come into contact with external audiences where the risk of corruption is considered high),
e-learning trainings (all employees or groups of employees with specific duties),
on the job trainings (visits to shops or when submitting queries on a dedicated communication line).
B] As far as the employees’ awareness regarding anti-corruption is concerned, OTE Group conducts, on an annual basis, communication campaigns:
1. In the framework of the International Anti-Corruption Day (9th of December), actions such as a Tone from the Top message by the Chairman of the BoD & CEO to all OTE Group employees, a relevant article on the intranet and a newsletter, give-aways, posters in public places and digital panels are included.
2. In the context of the International Fraud Awareness Week, a relevant article is published on the intranet as well as at the relevant official website supported by the Association of Certified Fraud Examiners/ACFE (www.fraudweek.com).
3. In order to create a culture of transparency and of zero tolerance to corruption or fraud, “Speak-up!” campaigns take place, which include articles on the intranet, newsletters and workshops for target audiences.
4. Guidelines to employees on Benefits (gifts and invitations) during Christmas and Easter periods. Additionally, when receiving socially acceptable gifts from business partners, a sticker is affixed to the gift package by the mail staff, which lists the Compliance communication channel (Ask-Me!) for relevant queries.
C] As far as the selection of business partners who respect our principles is concerned, we have adopted the following:
Business partners’ checks (pre-contractual integrity checks of prospective partners) according to the Compliance criteria. These criteria include anti-bribery law infringement in the past, negative publicity regarding the partner, as well as the inclusion of the partner to publicly available sanction lists. Relevant checks are performed regarding bodies / associations / NGOs, which the Group cooperates with in the framework of Donations / Sponsorships.
The Supplier Code of Conduct, which is uploaded on the corporate website and is accessible by suppliers. The acceptance of the Code is a prerequisite in order for a prospective supplier to enroll at the Suppliers’ Portal and also for signing a contract (the adherence to the Code is a contractual obligation). Moreover, the supplier must bind its contractors (and/or subcontractors) to adhere to the principles of the Supplier Code of Conduct insofar as they are involved in providing deliverables under the contract.
Anti-corruption clause, which is obligatory to be included as a term in contracts with suppliers /partners. In the above special clause, inter alia, it is mentioned that the supplier / partner and its subcontractors have the obligation, under the contract, to adhere to the principles and values (Rules) described in the “Code of Conduct” and the “Supplier Code of Conduct”.
