Anti-Bribery Policy

GELASAKIS S.A. declares a zero-tolerance approach to all forms of Active and Passive Bribery, and “Prohibits bribery in any form and any direct or indirect monetary or other type of payment (such as offering business opportunities, employment, favorable contracts, donations, trips, gifts, or hospitality) with the aim of gaining, maintaining, or securing (improper) advantage for the Company.”

In this context, the Company has incorporated the requirements of the ISO 37001:2016 “Anti-Bribery Management System” Standard into its Quality System and is committed to its implementation.

The preventive measures against bribery are expressed within the procedures of the Company’s Quality System and include:

• Identifying bribery risks.
• Complying with relevant legislative and regulatory frameworks related to bribery.
• Implementing policies and rules to ensure Ethical Transactions.
• Regularly reviewing the Policy’s suitability for the Company’s objectives.
• Establishing clear anti-bribery objectives.
• Conducting Due Diligence checks on involved personnel and business partners.
• Providing continuous training to staff to prevent bribery and encourage reporting of incidents.
• Offering protection for whistleblowers.
• Ensuring the Independence and Impartiality of the Anti-Bribery Structure.
• Providing an anonymous reporting mechanism.
• Conducting impartial investigations of bribery incidents and imposing consequences on those involved.

The principles of the system, as well as the anti-bribery objectives, are regularly reviewed by the Management to ensure continuous improvement.

The Management is committed to providing the necessary resources for the maintenance and implementation of the Anti-Bribery System.

Additionally, the Management is committed to upholding high standards of ethical conduct and expects supervisors, senior executives, employees, business partners, and other stakeholders with whom it collaborates to comply with this policy without exception.

All departments within the Company are responsible for responding to, assimilating, and implementing the procedures required by the Anti-Bribery System in their daily activities.

Furthermore, it is the responsibility of the Company's Management to ensure that the Anti-Bribery Policy is communicated, understood, and enforceable by all personnel and stakeholders of the Company.

Whistleblowing Policy

This Whistleblowing Policy aims to establish a system for the internal reporting of breaches of EU law, to protect the persons who report such breaches (hereinafter referred to as “whistleblowers”) and to organise the procedure for the submission, receipt and follow-up of reports.

The Policy is aligned with the principles and provisions of the Directive (EU) 2019/1937 of the EU on the protection of whistleblowers reporting violations of EU law, which has been incorporated in Greece by Law 4990/2022, as well as with international best practices developed for internal reporting.

Reports and complaints can be submitted in the following ways:

• Via email to the address [email protected].
• By mail for the attention of the person responsible for receiving and monitoring the reports at 6 Aristeidou Street, Piraeus, 185 31, Greece.
• Via telephone at +30 214 6878050 or another voicemail system, as well as through a personal meeting with the responsible for receiving and monitoring the Reports within a reasonable timeframe upon request by the reporter.