CORPORATE GOVERNANCE

OTE Group has adopted and applies across its functions and third party relations the UN Global Compact principles on human rights, labor standards, environment and anti-corruption.

In this context, we have established the Compliance Management System, under which we have developed our Compliance Program; one that promotes ethical behavior and integrity at all levels within OTE Group through the adoption of control mechanisms and international best practices.

The effective implementation of the Compliance Management System safeguards the reputation and corporate image of all Group companies, further consolidates their strong market position and strengthens relations of trust and transparency with our Customers, Suppliers, Partners, Employees and Shareholders. Ethical behavior, integrity and anti-corruption are a shared responsibility within our Group.

Michael Tsamaz , Chairman & CEO OTE Group                                                              

Aris Dimitriadis, Executive Director Compliance, Enterprise Risk Management & Insurance OTE Group

Compliance with legislation in force, with the OTE Group Code of Conduct and the internal Policies is of great importance to us.

Ensuring Compliance is a priority for the Company's Board of Directors.
Compliance stands for a solid commitment to the principles of integrity, transparency, fairness, professionalism, team spirit, and of respect for the rules; principles which are essential to govern the operation of the Group.

To that end, the Management has adopted and implemented a Compliance Management System (CMS), regarding the compliance of all (employees and management) with the legislation in force, with the Code of Conduct and with internal Policies, aiming to avoid risks and other legal consequences for the Group and its employees. In so doing, the benefit is for all: the Group per se, the employees, the customers and the suppliers of OTEGLOBE.

The effectiveness of the CMS relies on the commitment and the support of both management and employees.

The Company's CMS is reviewed by independent external auditors, who confirm the effectiveness of the procedures supporting it.

Key elements of the CMS

The prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the Group and its employees are protected from any legal consequences due to misconduct, while the reputational risks of the Group are reduced. Prevention is achieved mainly through:

• The employees' training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, manipulation of financial statements, leakage of confidential business information, etc.
• The channels that have been developed for the communication with employees, so that the latter can submit questions regarding the implementation of the Code of Conduct and the Policies, in case they are uncertain as to how they should handle issues that come up in their daily work.

The detection of compliance violations and the response to them. In order to provide the possibility of reporting any violations of Policies, regulations and of the legislation in force, the Company has established the relevant communication channels.

CMS Operation 

For the implementation of the CMS at the OTE Group, Compliance Officers have been designated at the Group subsidiary companies.
 

Management of Human Rights issues

Furthermore, the Company has designated on a corporate level a responsible Officer for managing Human Rights issues, to whom, together with the designated persons in the group companies, internal and external inquiries as well as any relevant tip offs are addressed.

OTEGLOBE declares that it complies with the applicable laws and strives to comply with the international standards so as not to violate human rights and, to this end, it has adopted and applies the "Code of Human Rights & Social Principles", as binding on all Group companies.

In the context of implementation of the Compliance Management System, the following Policies and Codes are in force:

• OTE Group Code of Conduct
• OTE Group Policy on Avoiding Corruption and other Conflicts of Interest
• OTE Group Code of Ethics for Senior Financial Officers
• OTE Group Whistleblowing Policy
• Binding Corporate Rules Privacy
• OTE Group Policy on Ιnsider Τrading
• OTE Group Policy on Anti-Trust Law
• OTE Group Donation Policy
• OTE Group Sponsoring Policy
• OTE Group Policy on Accepting and Granting of Benefits
• OTE Group Anti-Fraud Policy
• OTE Group Event Policy
• Policy on Avoiding Sexual Harassment within OTE Group
• Policy on Employee Relations within OTE Group
• OTE Group Corporate Responsibility Policy

Incidents of Misconduct

You may report incidents regarding violations of company Policies, Procedures or applicable laws (e.g. fraud, corruption, theft, embezzlement, money laundering, falsifying accounting records and financial statements, non-compliance with the OTE Group Code of Conduct, or/and OTE Group Policies, issues relating to human rights and in general, any act or omission which could harm the Company or its reputation) by using the communication channels mentioned below:

• Via e-mail:  whistleblowing@oteglobe.gr or tellmecompliance@oteglobe.gr
• Via telephone: +30 210 8762636 (Monday through Friday: 10am until 5pm)
• Via fax: +30 210 8762600
• Via mail: OTEGLOBE
  Compliance Office 6-8 Agissilaou str., 151 23 Maroussi, Athens, Greece

Employees or third parties who provide information on wrongdoing or violations of corporate Policies, as well as employees or third parties mentioned or included in those tip-offs shall have the right to obtain access to the personal data, to obtain information as to whether or not personal data concerning him or her are being processed, shall have the right to object, to obtain rectification of inaccurate personal data, as well as to request at any time and without charge the erasure of personal data they have provided under the terms of the General Data Protection Regulation (EU 679/2016-GDPR).