INDICATOR: 102-17

We are committed to being a responsible Group. This means that we conduct our activities in accordance with relevant ethical, professional and legal standards. Corruption, bribery and unfair competition are unacceptable.

Sustainability related risks, such as employees, safety, the environment, ethics and supply chain management, are an integral part of Group Risk Management. For each of the risk categories, related to the Group and each company, a risk assessment takes place together with the determining potential for improvement.

Therefore the Hellenic Petroleum Group’s Code of Ethics explicitly provides that each employee must comply with the law and behave honestly, transparently and responsibly towards clients, associates, shareholders, and social partners in general. It provides the possibility for counselling on ethical and legal behaviour issues as well as providing the opportunity for employees to submit anonymous related reports to the Regulatory Compliance Office, with full confidentiality. The Code of Conduct has been translated into all the languages ​​of the countries where the Group operates and is also applied there.

Since June 2017, Hellenic Petroleum has been a member of the Business Integrity Forum of the Hellenic Office of the INTERNATIONAL TRANSPARENCY organization, where, in cooperation with other major companies operating in Greece, exchanges knowledge and best practices for dealing with corruption.

ΟΚΤΑ:

• We have implemented a mechanism to protect workers’ rights, in accordance with the Law. We have developed measures and procedures against harassment in the workplace. An independent internal audit service operates.
• We have implemented mechanism for protection of the personal data of our clients and employees, as well as our employees’ rights in accordance with the Law
• We have implemented measures and procedures for security of the company assets.
• Regular trainings for our new contractors, truck drivers and employees are being performed in reference to the health, safety and environmental issues and internal procedures.
• Monthly FF Drills are performed in accordance with different scenarios for all employees who are working in shifts.
• Existence of an independent internal audit department.

HPCYPRUS:

The Group’s Code of Conduct was implemented in 2012. The Code manages all of these aspects and has been communicated to all employees, suppliers and customers, and also constitutes part of all of our contracts.

EKO Bulgaria:

The reporting mechanisms and associated procedures are described in the Code of Conduct. The obligation to comply with the Code of Conduct is included in the agreement with each partner. Concerns are treated confidentially. The Company does not follow a retaliation policy. No concerns have been raised.

EKO Serbia:

The Group’s Code of Conduct is in place and has been outsourced to an external partner (email 24/7, free phone line 07:00-22:00). Depending on the type of complaint (concern), appropriate staff investigate the matter at hand and prepares the final response. For the communication with stakeholders several channels of communication re used: (Corporate Web site, Loyalty Portal, Android and IOS application, newsletters, bulk SMS and Viber, Memo letters, customer service line, petrol stations employees)

According to the law all complaints officially received have to be resolved within 15 days, while 8 days is deadline for first answer to customer. The Code of Conduct is undergoing an evaluation and review process that builds on experience gained from its implementation and incorporates new legislation. At the meeting on 22/3/2018, the Company’s BoD approved the Group’s Competition Policy and Compliance Program. During 2018 (Board of Directors Decision 1321/4 / 10.5.2018) the Group’s Privacy Policy was adopted in compliance with the applicable national and European regulatory framework and in particular the European General Data Protection Regulation (GDPR).

According to Chapter 6 of the Code of Conduct, a conflict of interest arises when personal relationships, external activities or interests in other businesses affect or could affect any employee’s decisions in the performance of his/her duties. When these situations occur they are a matter of fact and must be treated on a case-by-case basis. This type of conflict of interests that arises between a person or member of an employee’s family and the interests of the Group is often not easily understood, as there are cases that create confusion and doubt.

The Company intends to adopt a conflict prevention policy within 2019 that will be part of the Code of Conduct.