Code of Ethics

Code of Professional Ethics

One of the most important pillars of our company’s good reputation is our dedicated and responsible staff. This policy refers to the expectations of ERGON TZANIDAKIS Ltd in relation to the behaviour of its employees towards colleagues, supervisors, customers, suppliers and the business in general.
Although we promote freedom of expression and open channels of communication, all employees are required to adhere to a code of conduct. It is necessary to avoid insults, participation in serious arguments and conflicts in the workplace. It is also important to have a well-organized environment that promotes respect and cooperation.
This policy describes the conduct that should be demonstrated by ERGON TZANIDAKIS LTD employees and their business partners. At the same time, it describes the types of behavior that are not tolerated. The way we do business should be based on honesty, integrity and fair competition. It is not only what our customers and business partners demand of us, but it is also the way to create a good working environment for everyone.
The employees of ERGON TZANIDAKIS LTD are committed by the terms of their contracts to comply with specific guidelines that they apply in their working environment. All employees are obliged to know and follow the Code of Conduct.

1. COMPLIANCE WITH LAWS AND SOCIETY RULES

ERGON TZANIDAKIS is committed to fully comply with all applicable laws and regulations. This Code of Conduct does not supersede or supersede local laws and regulations. It is a set of complementary principles and standards of behavior that do not have a legal character.

2. WORKING ENVIRONMENT

ERGON TZANIDAKIS LTD seeks to create and maintain an environment in which each employee is treated as an individual and can work to his/her full potential. ERGON TZANIDAKIS LTD respects human rights, as set out in the United Nations Universal Declaration of Human Rights and fundamental labour rights as defined by the International Labour Organisation. In carrying out its activities, ERGON TZANIDAKIS LTD respects the freedom of association and the right to collective bargaining. Especially in the case where these rights are restricted by local legislation, ERGON TZANIDAKIS LTD encourages employees to engage in dialogue with management, and to report any grievances.

2.1 Non-discrimination
All employees of ERGON TZANIDAKIS LTD must be treated fairly and equally by the management, as well as by their colleagues. ERGON TZANIDAKIS LTD is committed to implementing an equal opportunities policy that prohibits discrimination of any kind. Diversity is promoted and valued.

2.2 Safety and Health
Every employee of ERGON TZANIDAKIS LTD has the right to a safe and healthy working environment. Each employee is responsible to comply with the safety procedures and guidelines of ERGON JANIDAKIS LTD. We encourage all employees to report safety issues concerning other ERGON TZANIDAKIS employees to their supervisor.

2.3 Prohibition of harassing behavior and sexual harassment
ERGON TZANIDAKIS LTD firmly believes that every employee has the right to protection against any violation of his/her personal integrity. Harassment of any kind, direct or indirect, physical or verbal, regardless of its intent, is prohibited. Any aggressive or disruptive behavior will not be tolerated. The above is especially true in cases of sexual harassment by any person, including supervisors, co-workers, customers or suppliers. Such harassment will not be tolerated under any circumstances. Sexual harassment can take the form of unwanted sexual behavior or comments of a sexual nature on or off the job.

2.4 Child or Forced Labor
ERGON TZANIDAKIS LTD does not use child or forced labour, nor does it cooperate with suppliers or subcontractors who use such labour.

2.5 Computer and e-mail
Staff may occasionally use the computers and communication equipment owned by ERGON TZANIDAKIS LTD and provided to them for their use, including the e-mail system, for personal matters, but such personal use should be kept to a minimum. Any use of ERGON JANIDAKIS LTD’s computers and communication equipment should be responsible, professional and in accordance with company policies. ERGON TZANIDAKIS LTD’s computers and communication equipment may not be used under any circumstances to engage in illegal, fraudulent or malicious activities, nor for the transmission or storage of offensive, obscene (e.g. pornographic) or political material.

3. COMPETITION AND FAIR DEALING IN TRANSACTIONS

ERGON TZANIDAKIS LTD strives to achieve its objectives through high performance, by developing and marketing products of excellent quality at advantageous prices compared to its competitors, always using fair and lawful means, always acting with honesty and avoiding any unethical or illegal business practice. Stealing proprietary information or divulging trade secret information obtained without the owner’s consent, or causing such disclosures, both by current employees and staff of ERGON TZANIDAKIS Ltd. and by former employees of ERGON TZANIDAKIS Ltd. Every employee must respect the rights and deal fairly with other employees as well as with its customers, suppliers, contractors and competitors. Employees may not take unfair advantage of anyone, whether through manipulation, concealment or exploitation of privileged information, or misrepresentation of facts, or through any other illegal business practice. No employee may engage in price-fixing negotiations, bid-rigging, agreements regarding sales shares and allocation of markets or customers, and generally in any illegal activity or unethical practice that impedes healthy competition.
The purpose of corporate gifts in a commercial relationship is to create a positive atmosphere and suitable working conditions for the progress of the work, and in no case to gain an unfair advantage over other customers or suppliers.
No gift shall be offered or accepted by any employee, relative or associate of such employee unless it: (1) is not a gift of cash, (2) does not violate any law, regulation or applicable policy of another, (3) cannot be perceived as a bribe or kickback or attempted influence, (4) is consistent with normal business practices, (5) is reasonable in value.
It is the responsibility of each employee to exercise fair and sound judgment in this area. In case of doubt, the employee should seek information and guidance from his supervisor, the legal department and the management of ERGON TZANIDAKIS, in order to act in a sober manner.

4. AVOIDANCE OF BRIBERY AND CORRUPTION

ERGON TZANIDAKIS LTD condemns any kind of corrupt professional behaviour and any form of bribery. It is not permitted for anyone acting on behalf of the company to offer or provide (directly or indirectly) any form of unfair benefit or other advantage to a natural or legal person in the Private or Public Sector, with the ultimate aim of securing or maintaining or to expand business activity. By extension, he must not accept any such advantage in exchange for the purpose of any preferential treatment associated with it.
In addition, any employee, officer or member of the management of ERGON TZANIDAKIS LTD must refrain from any activity or conduct that could give rise to the appearance or suspicion of such a transaction or attempt to this authority.
Promising, offering or providing a gift, payment or other benefit to a public official of the Greek or foreign State, in violation of the rules of this Code, is not only contrary to the policy of ERGON TZANIDAKIS LTD, but may constitute a serious civil and / or criminal offence.
Business gifts and offers of hospitality may be provided and accepted as acts of courtesy that help promote the relationship between the parties, provided they are provided in compliance with applicable laws and do not violate this Code of Conduct. Token gifts of low value (eg pens, diaries, notebooks, etc.) may be accepted and offered. Gifts or benefits that are unreasonable in nature, frequency or value are prohibited. It is prohibited to offer or accept a monetary gift regardless of amount or currency. Any reasonable entertainment activity or other type of corporate hospitality as part of a business relationship is acceptable, e.g. work lunches or social or educational events, if they fall into the following categories:
• offered as part of a bona fide business relationship
• offered as part of an educational or business event/ function
• is legal
• complies with applicable industry codes
• complies with company policies and procedures
• will not be perceived as an attempt to unfairly influence business decisions
In the context of informing mainly the professionals of the sector to which our company’s products are addressed, educational items or training benefits and internship opportunities may be offered, provided that they are directly relevant to the professional object of the recipient and have an exclusively educational purpose.

5. ENVIRONMENT AND SUSTAINABILITY

Sustainability means responsibility for the economic, environmental and social impacts of ERGON TZANIDAKIS Ltd’s activities. ERGON TZANIDAKIS LTD is sensitive to environmental protection issues and encourages its staff and partners to always adopt, both inside and outside the workplace, the best practices of a responsible consumer to reduce pollutants and carbon dioxide emissions from combustion.

6. AVAILABILITY OF PRODUCTS AND SERVICES

Any statements, announcements, disclosures, and certifications provided to customers and business partners must be true and correct. ERGON TZANIDAKIS LTD does not disparage any of its competitors’ products, services or employees. All products we offer must comply with all applicable quality and safety regulations and our promises in relation to them.

7. RISKS AND CONFLICTS

7.1 Conflict of Interest
ERGON TZANIDAKIS LTD expects its employees to be loyal and to make business decisions in the best interest of ERGON TZANIDAKIS LTD. ERGON TZANIDAKIS LTD employees must avoid any conflict of interest, i.e. situations where their personal interests may be or appear to be in conflict with those of ERGON TZANIDAKIS LTD. They must disclose all potential and existing conflicts of interest in writing to their supervisor.
Potential conflicts of interest may arise when an employee or a member of their immediate family environment:
• Act as an employee, director, intermediary or consultant to any entity that is a competitor, customer or supplier of ERGON JANIDAKIS LTD.
• Has a greater than 5% financial interest in any company with which ERGON TZANIDAKIS LTD has a current partnership or competes.
• Acquires any property, leases, patents or other ownership or rights in which ERGON TZANIDAKIS LTD has an interest or intends to have an interest.
• Influences or directs the involvement of ERGON TZANIDAKIS LTD to a friend or relative.
• Accept any form of loan or payment from a customer or supplier of ERGON TZANIDAKIS LTD in exchange for a business transaction, acceptance of increased prices or unacceptable levels of service (e.g. sub-standard quality or receipt of short shipments) or any other treatment that adversely affects ERGON TZANIDAKIS LTD. Such payments may be considered bribes or kickbacks, which are strictly prohibited.

7.2 External Work and Participation in a Board of Directors of any kind
Any employee of ERGON TZANIDAKIS LTD who wishes to be employed externally or to perform management duties outside the company, should notify ERGON TZANIDAKIS LTD of this intention. Such activity may be acceptable provided that it does not conflict with the employee’s responsibilities and does not create a potential or apparent conflict of interest. Such activity is always subject to the prior approval of the employee’s supervisor.

7.3 Investments
Employees must declare to ERGON TZANIDAKIS LTD any financial interest, either direct or indirect, which they or members of their immediate family have in any business or company that is a competitor of ERGON TZANIDAKIS LTD or with which ERGON TZANIDAKIS LTD cooperates, except for purely financial interests in a listed company.

7.4 Anti-fraud
The funds and assets of ERGON TZANIDAKIS LTD must always be used in a responsible manner and for the intended and legal purposes. Any information provided to ERGON TZANIDAKIS Ltd. in the event that reimbursement or compensation, benefits or approvals are sought for the use of ERGON TZANIDAKIS Ltd. assets must always be accurate and reliable. Any kind of theft, fraud, misappropriation and misuse of ERGON JANIDAKIS LTD assets is prohibited.

7.5 Political Activities and Sponsorships
ERGON TZANIDAKIS LTD recognizes and values the freedom of each of its employees to choose a political opinion. However, in order to ensure that the expression of any political views by ERGON TZANIDAKIS Ltd. employees cannot possibly offend any of their colleagues, no political activities or political beliefs should be carried out on the premises and at any ERGON TZANIDAKIS Ltd. work events.

8. HANDLING OF INFORMATION

8.1 Information Security and Intellectual Property Rights
Information is a valuable company asset. ERGON TZANIDAKIS LTD preserves the confidentiality, integrity and availability of its private information. All employees of ERGON TZANIDAKIS LTD are responsible for the proper protection of its assets, including its intellectual property and confidential information.

8.2 Data Protection
ERGON TZANIDAKIS LTD is committed to protecting personal data. Any processing of personal data of employees, customers, suppliers or other persons carried out by ERGON TZANIDAKIS LTD must be lawful, fair and transparent to the persons concerned. In addition, the processing of personal data must be carried out in accordance with the law.

8.3 Confidential Information and Securities Trading
It is both illegal and contrary to ERGON TZANIDAKIS Ltd’s policy for any of its employees to exploit confidential information about ERGON TZANIDAKIS Ltd or any company with which it does business in order to gain an advantage. It is also prohibited to use any such information for the benefit of any third party. Until it is published, any material information regarding ERGON TZANIDAKIS LTD or its business activity is considered confidential.
The obligation to keep confidential information confidential is binding even after the termination of employment or termination of the relationship in any way, even if otherwise provided for in the relevant contract. Confidential information is defined as information held by ERGON TZANIDAKIS Ltd, or information that its suppliers and customers have entrusted to it, as well as all non-public information, the disclosure of which could be harmful to the company, its customers, suppliers, contractors or partners, or useful to its competitors, or contrary to the interests of ERGON TZANIDAKIS Ltd.

8.4 Financial Information
All corporate reports and reports submitted by ERGON TZANIDAKIS LTD must comply with applicable accounting standards and other applicable rules and be accurate and reliable in all material aspects. All legally required financial statements and reports must comply with the laws, rules and standards applicable to the particular type of information.
The employees of ERGON TZANIDAKIS LTD are obliged to prepare documents, reports and generally service notes in a timely and responsible manner, as well as to check the completeness and correctness of the information they provide, in order to enable the Management to make responsible and correct business decisions. Every business expense must be documented and recorded in a timely and accurate manner. All books, records, accounts, financial data and financial statements must be kept in detail and accurately reflect its transactions. Also, they must be disclosed immediately when this is provided for by the Law as well as be harmonized with the company’s internal control system and the applicable legislation.

9. REPORTING ILLEGAL OR IMMORAL CONDUCT

Employees and staff of ERGON TZANIDAKIS LTD are encouraged to openly address their supervisors, the Management or the Legal Department, as the case may be, for the best possible response to any identified or possible or doubtful violation of the Code of Conduct, the general corporate policy or the applicable legislation. It is ERGON TZANIDAKIS LTD’s policy not to allow third parties to retaliate or discriminate against personnel who in good faith make such reports in order to protect its interests. Also, employees must cooperate during an internal investigation of such cases.

I have carefully read this LSC document and confirm that I understand and agree to its provisions.