ECONOMY

At the heart of the Code of Conduct we use are our Business Principles which are the basis on which we conduct our business activities, wherever and whenever we operate. More specifically, we act fairly with honesty and integrity in our dealings, both internally and externally.

Our business principles in brief:

› Individual behavior

› Contact

› Compliance with legislation

› Customers

› Health and safety

› Employees

› Financial Integrity

› Communities and Society

› Public administration

›Environment

Policy against bribery and corruption

The Vodafone Group has implemented an anti-bribery and corruption policy since 2008 in all countries in which it operates, including Vodafone Greece (Anti-bribery Compliance Policy). This policy was first revised in June 2011 to bring it in line with the requirements of the UK Bribery Act 2010 and has since been revised several times.

At Vodafone, in March 2012, we proceeded to issue the "Policy of compliance with the law against bribery and corruption", which is harmonized with the policies of the Vodafone Group, but also with the corresponding provisions of the relevant national legislation.

The basic principle to be observed against bribery and corruption is zero tolerance, where all Vodafone employees must not accept or engage in any form of bribery/corruption.To ensure full alignment with this principle, we implement the following:

a) Systematic information (through presentations and an e-learning program) of Management members and employees, regarding the requirements of the laws, the ways to deal with situations related to active and passive bribery, as well as the ways to report incidents of bribery.

b) Informing the company's suppliers, regarding the new requirements and introduction of special conditions in the existing contracts based on the directions of the Vodafone Group as well as the possibility of informing and reporting incidents of bribery to a specific email through the "Speak up" program.

c) Procedure for reporting cases of bribery (anonymous or named) by the company's employees through the "Speak up" program.

d) Signing by the Administrative Team of a relevant declaration of acceptance of the Code of Conduct and commitment to its implementation (the Code also includes anti-bribery issues).

e) Carrying out biennial risk assessment exercises, through meetings, in the company's Departments whose activities are related to specific high-risk areas.

In the Code of Conduct of the Vodafone Group, but also of Vodafone, there is a special paragraph on the obligation to comply with the specific legislation.

During the period 2020-2021 there was no relevant incident of non-compliance.

In addition to the above, no form of bribery, including improper offers or financing to or from employees, is tolerated. We avoid any agreement that may lead to or imply a possible conflict between personal activities and the company. We do not offer or accept hospitality or gifts that may give the impression of an obligation or personal commitment. We do not make gifts or donations to political parties or interfere in party matters.

We seek mutually beneficial relationships and seek ways to enhance the implementation of our business principles by our partners and suppliers. We comply with the applicable provisions of each national and international legislation as well as with the relevant standards and principles. Our investment decisions, purchases and business relationships are based on economic criteria, taking into account social and environmental parameters. We protect the health, safety and well-being of our customers, our employees, our partners and the communities where we operate. We disclose any information that comes to our attention if it clearly indicates that a product or service of ours violates internationally accepted safety standards or guidelines.

Speak Up Program

The Speak Up program was developed in 2006, for the anonymous reporting of incidents that do not comply with Vodafone's Code of Conduct, policies and procedures through a telephone line and a dedicated website. The program complements Vodafone's open communication culture where all employees feel comfortable speaking to their supervisor or head of HR about potential mistakes that come to our attention, thus confirming that we are all working in accordance with our business principles .

All reports are treated in strict confidence regardless of the manner and medium of disclosure. The company is committed to the timely investigation and resolution of all reported cases, while at the same time offering protection from any retaliation and discretionary treatment to persons who disclose reprehensible behavior in good faith.

Of the incidents reported and investigated during 2020-2021, none were high-risk incidents, such as a bribery or Competition Law report.

Vodafone Group high risk policies and ongoing compliance monitoring

Vodafone is committed to implementing high levels of Corporate Governance, which are of the utmost importance to achieve business integrity and to maintain the trust of all stakeholders. In this context, a comprehensive compliance empowerment and monitoring program has been developed and implemented with actions coordinated at the local level as well as at the Group level based on the High Risk Policies. Through this program, the high-risk areas are identified and redefined at regular intervals and the corresponding measures are applied for their preventive treatment.

On an annual basis, the Vodafone Group plans the Annual Review of all High Risk Policies in collaboration with the local compliance teams, and the relevant compliance actions are monitored at the meetings of the Audit and Risk Committees at the local level, as well as at the Group level. The aim is to ensure a high level of compliance as well as to record measurable areas for improvement. The methodology is common within the Group, adapted to the risks posed to the organization by non-compliance with the policies, while the use of specialized staff within the organization for the assessment ensures the reliability of the results and a consistent image of compliance to Management.

In addition, there is the Vodafone Group Corporate Governance and Policy Manual which all local member companies must follow and which is revised at regular intervals.

Internal Audit Service

Vodafone's Internal Audit Service is part of the unified assurance model that the company follows with the aim of optimizing and aligning risk management actions. The main role of the service is the independent and objective examination of the company's operation and the proposal of ways to optimize it based on practices of other companies of the Group, as well as generally accepted practices of corporate governance and control. The annual control plan is created based on the company's estimated exposure to significant risks.

The estimated report is based on the risk assessment and the self-assessment of control mechanisms by the Management, but also on the independent assessment of the Internal Audit. In order to ensure the high level of services during the execution of the plan, there is the active participation of specialized auditors from other companies