Code of Conduct Hellenic Dairies S.A.
Trust is the key to success for HELLENIC DAIRIES S.A. In order to be trusted, we must behave according to the highest ethical standards. At the same time, we protect our reputation and reduce the cost of our business activities. Integrity in our behavior means that we always do the right thing and starts by acting according to our Code of Conduct. It is our duty to act with integrity and to urge others to do the same.
Contents
Management’s message
page 04
Introduction
page 05
Vision, mission and commitment
page 06
Principles governing our workplace
page 08
Health and safety
page 08
Diversity, equal opportunities
page 10
Working without harassment and violence
page
Information security and personal data
page 12
Assets
page 13
Principles governing our business practices
11
page 14
Product quality and safety
page 14
Contact us for products
page 15
Selection of partners
page 16
Fair competition
page 16
Conflict of interest
page 17
Gifts, hospitality and entertainment
page 18
Book and record keeping
page 19
Principles governing our attitude towards the environment and society
page 20
Human rights
page 20
Environment
page 21
Sustainable development
page 22
Social participation and local communities
page 23
Clients and consumers
page 24
Communicating with the media
page 24
Advice and guidance on the implementation of the Code
page 25
Hellenic Dairies – Code of Conduct
Management’s message Hellenic Dairies is the leading force in the Greek dairy industry and one of the country’s biggest food companies. Its evolution bases its success on the company’s continuous investment in human capital. Its positive financial results, progress and development are primarily due to its employees. The Code of Conduct defines and ensures the activity of the company’s people within a context of transparency and honesty. A guide on ethical business practices, which helps to preserve a working environment worthy of the company’s name. The combination of this Code with the principles and values of Hellenic Dairies is the basis for building trust as the foundation of its business success. Honesty, transparency, innovation, social and environmental responsibility are the valuable heritage of our company and part of its culture. A culture based on the professional activity of our family and specifically the expertise and hard work of our father during the times of our first cheese factory. As the company’s Management, we are responsible for shaping and preserving a pleasant working environment, where relations between people of the company are characterized by dignity, respect and solidarity. We promote equal employment opportunities, consistent with the conditions laid down in labor legislation, and adopt recruitment criteria and practices based on each individual’s abilities and educational attainment, regardless of gender, nationality, color, origin or sexual orientation. Hellenic Dairies provides for the training of its human resources, ensuring the conditions for enhancing the creative expression of employees and the fulfillment of their professional ambitions. Employees should be aware that business ethics is not just limited to complying with legal, regulatory, professional and business standards. In addition, it represents the development of business activity in a spirit of fairness, integrity, honesty and respect. Hellenic Dairies fully respects the laws concerning intellectual property by preserving the confidentiality of employees’ records, allowing their use only by authorized persons for legitimate purposes related exclusively to its business activity. The Code of Conduct is a guide for decision-making. We all have an obligation to respect it, defending the company’s reputation that was built over the years. The way in which our values and principles are served, especially during difficult and demanding times, is a source of pride for our company, as we all share the obligation to meet the expectations of consumers, clients, suppliers, and society as a whole. Our mission is to provide top quality products that contribute to the healthy and balanced diet of modern people. We are all devoted to it. The Chairman
The Chief Executive Officer
Dimitris Sarantis
Michalis Sarantis
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Introduction Purpose of the Code The purpose of the Code of Conduct is to set the standards of conduct that we have to follow in order to respect the ethical principles of the company. The aim of the Code is to provide general guidance on a number of situations we may face during our work. The Code cannot describe every possible situation and does not intend to replace the soundness and common sense which are always required.
To whom it applies This Code of Conduct applies to all employees at Hellenic Dairies and their subsidiaries, namely the Chairman and the Chief Executive Officer, the members of the Board of Directors, as well as all employees. It also applies to consultants, partners and any other persons whose work is equivalent to the work performed by employees at Hellenic Dairies, as well as to suppliers. When implementing the Code of Conduct, the company respects the laws and regulations of our country. Legally and morally sound behavior is the responsibility of all of us. At Hellenic Dairies we set and achieve our goals while at the same time behave in a responsible and exemplary way. For managers and heads of departments, this means that they are responsible for acting as role models for employees, through their actions. They also ensure that employees know and adhere to the Code of Conduct. In order to ensure that such behavior can be reported, we provide an environment where employees can report any misconduct without fearing any negative consequences.
The company’s relationship with its employees is based on mutual trust and the desire for close and sincere cooperation. Adherence to the Code is a prerequisite for this mutual trust and cooperation.
Violation of our Code We are all responsible and obliged to implement the Code. Any violations of the Code, our policies, our instructions or the law may have serious consequences, including disciplinary measures up to termination of employment, as well as possible civil or criminal sanctions, both for the company and for employees.
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Hellenic Dairies – Code of Conduct
Vision, mission and commitment The insistence on quality and the dedication to traditional taste were the main ingredients of the first dairy products that were produced by the small cheese factory of Stergios Sarantis. These are the features we still preserve, characterizing each product that bears our company’s signature.
Mission Having three generations of experience and dedication to the values of the past, we are devoted to offering top quality products that contribute to the healthy and balanced diet of modern people.
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Our values Our values are the guide we follow and are the ones listed below:
High quality The quality and safety of products are a moral commitment for us and are reflected at all stages of the production process, namely the careful collection of raw materials, their processing, the sanitary packaging method and the excellent storage conditions, thus offering consumers products of superior quality.
Respect for our people We respect each individual, so we invest in the continuous training of our employees, thus caring for a better working environment.
Trust Trust is a foundation for our development. Every day we work hard to be worthy of the relationship of trust that we have developed with our consumers, clients, employees and society as a whole. The constant preference of consumers to the products of Hellenic Dairies not only contributes to the continuous development of the company, but also to the sizes of Greek economy through primary production based purely on Greek values.
Greekness We are truly oriented to the production of products with Greek raw materials, thus preserving Greek primary production and strengthening Greek producers.
Authenticity The favorite authentic taste of our products remains unchanged. And this is because our products are made from Greek raw materials of high quality and nutritional value, according to the traditional Greek way.
Sustainability We know that the growth of economy depends directly on the sustainability of our ecosystem. We actively contribute to the protection of the environment and the saving of our natural resources by minimizing the impact of our activities on natural environment. We recognize our responsibility towards society, which is why we make sure every day that we are worthy of its trust.
Our vision: A more natural and nutritious diet for all
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Hellenic Dairies – Code of Conduct
Principles governing our workplace Health and safety Hellenic Dairies is committed to providing a working environment that protects the Health and Safety of its employees, partners, clients and other stakeholders.
Protecting Health and Safety at work is a top priority for Hellenic Dairies. Our constant goal is to have zero accidents at work. The company takes all appropriate measures within its sphere of influence to guarantee the safety of both people and equipment and its facilities and aims to protect them against any foreseeable emergency. Therefore, the company is fully aligned with the relevant legislation, regulations, international standards and best practices, aiming to ensure the best and at the same time secure working conditions in terms of health and safety. Preserving and improving these working conditions in the above fields is the responsibility of both the company and each employee individually. In addition to ensuring access to safe and clean areas for eating and having breaks, the company always provides the most suitable and effective personal protective equipment, as well as appropriate training for all employees. Finally, apart from the compulsory social security provided, Hellenic Dairies offers adequate medical care, while it has an occupational doctor who sees employees in accordance with the provisions of law and following a schedule which is always specified by the company’s Management. At the same time, it promotes a context of safety at work, by raising awareness regarding the risks and use of all necessary resources to guarantee the safety and health of those working at it. This encourages the reporting of issues that may arise and are resolved with the support of the Safety Technician.
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Health and Safety rules Ensuring Health and Safety at work is a fundamental value for Hellenic Dairies and this means strict compliance with the following five rules: 1. Before starting any work, I assess the risk and take all necessary control and protection measures. 2. I only perform the tasks assigned to me and in the manner required. 3. I never forget or misuse the Hygiene and Safety equipment and always use the required personal protective equipment. 4. I always work with clear mind. I do not work under the influence of alcohol/ other substances or when I feel sick. 5. I report all safety incidents, including near accidents.
In all cases of injury or near injury, employees must report the incident to the Safety Technician, the occupational doctor and the company’s Human Resources Department for recording in the Special Incident and Accident Book. At any time employees are able to contact the Safety Technician and the Head of each department for matters they observe regarding unsafe situations or practices.
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Hellenic Dairies – Code of Conduct
Diversity, equal opportunities We have a responsibility to treat each other with politeness, respect and dignity by demonstrating professionalism. We recognize diversity as a factor that enriches our business decisions and we ensure equal opportunities for all. We respect diversity and avoid any discrimination based on age, gender, sexual orientation, disability, social background, race, nationality, political or religious beliefs and any other criteria of diversity, thus promoting fundamental personal rights and freedoms. Our main concern is that all employees, regardless of the job title or level in the corporate ladder, are treated fairly and participate in issues related to education, recruitment, remuneration, evolution and termination of the employment relationship, based exclusively on criteria such as the qualifications, experience and participation in the company’s efficiency. This way we ensure a non-discriminatory behavior towards all our colleagues, clients and partners. Furthermore, we communicate openly and transparently, and work together to build trustworthy partnerships to achieve our goals. This is why any abusive behavior, harassment or intimidation is rejected and condemned as unacceptable.
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Working without harassment and violence We reassure the shaping and preservation of a pleasant environment where relations between people are governed by dignity, respect and solidarity, while there is no psychological, verbal or physical violence. We preserve a workplace that is free from inappropriate and non-professional behavior, such as violence, harassment and intimidation. Harassment may take many forms, but usually involves verbal or physical behavior that leads to intimidation, threat or even humiliation of employees. Harassment also includes degrading or humiliating jokes, unwanted sexual approaches and offensive, verbal, visual or physical behavior. This includes the display or distribution of any kind of offensive material such as inappropriate images, animations, jokes or hate symbols, at any location or facility of the employment (e.g. offices, break rooms, company computers). Violence of all kinds is completely contrary to our commitment to treat all staff with dignity and respect by forming reliable partnerships. We therefore urge you, if you believe that you are experiencing any kind of harassment, intimidation or other inappropriate and unprofessional behavior, or even if you are a witness to any of these behaviors, to report your concerns.
Question: What is the acceptable way of behaving at our workplace? Answer: We have a responsibility to treat each other with politeness, respect and dignity by demonstrating professionalism. We recognize diversity as a factor that enriches our business decisions and we ensure equal opportunities for all.
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Hellenic Dairies – Code of Conduct
Information security and personal data We pay the utmost attention to preserving the security of information as well as the personal data we handle. The ever-increasing use of technology in the workplace allows us to serve our suppliers, clients, partners and employees more and more effectively. However, at the same time, it poses risks to the protection of both information and any type of personal data, both sensitive and non-sensitive. We always care for protecting the company’s own information, as well as the information and personal data that have been communicated by employees, clients, suppliers and other business partners with due diligence; we apply the appropriate technical and organizational means available to us in order to prevent unauthorized access to them, their unlawful appropriation, loss, destruction or early deletion. Our attitude also refers to records/personal data of candidates, current or future employees, including performance assessments, salaries, pensions and benefits. The technological evolution of communication, which has led to the ease and speed of data exchange combined with the expansion of use of social media, allows us to communicate directly and widely. Each one of us is required to think carefully before disseminating or reproducing images and/or text relating to persons (colleagues, partners, suppliers, clients) or our workplace. The irresponsible attitude and use of the tools offered by the development of technology in the context of communication can have unpredictable effects and be harmful both to the personality and reputation of individuals and to the reputation and activities of the company.
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Assets We protect the company’s assets, both intangible and tangible, in the best way possible. The tangible assets of Hellenic Dairies, such as equipment, materials and facilities, are crucial for the performance of our daily work. These assets have been accumulated through the hard work of many people over time and give us the means to evolve and perform our duties effectively. Therefore, we need to protect them and to preserve these resources, preventing their damage, theft, abuse or wasting. In addition, we must ensure that they are used for appropriate business purposes, thus making reasonable use and restricting the personal use of communication tools such as corporate e-mails, telephones, photocopiers or devices to what is strictly necessary, and only if it does not interfere with the work responsibilities nor results in significant additional costs for the company. Moreover, it is not permitted to use corporate computer systems and technologies to receive, view or send material that is illegal, offensive or inappropriate. Copying software for personal use is prohibited. If you have any questions or concerns about whether you are handling the company’s equipment properly, you should discuss with your manager.
Question: Can we use or remove excess equipment (e.g. a printer), left unused or replaced? Answer: No. Even if they are assets that are not used, they remain the property of Hellenic Dairies, so any use/moving/removal of these assets is subject to the company’s consent.
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Hellenic Dairies – Code of Conduct
Principles governing our business practices Product quality and safety The high quality of products is a non-negotiable value for Hellenic Dairies. We make every effort to offer our clients products of excellent quality and safety. In order to ensure the high quality of products, the company has three main tools: the specialized knowledge of its scientists, the advanced technology of its facilities, as well as the modern systems for monitoring the processes at all stages of the production process and in all facilities. At the same time, the company, in order to ensure the production of excellent quality products, has specified basic procedures and controls from the collection of raw material to the disposal of the product to the final consumer. Meanwhile, it seeks to continuously improve the processes it follows, ensuring general requirements of high hygiene everywhere in relation to all its premises. Responsibility for following the methodology in terms of recognizing, assessing and controlling food safety risks lies with the Food Safety Team, which, taking into account new scientific data, is committed to meeting the requirements of legislation and competent authorities and of course clients. For this reason, all employees involved in any way in quality assurance, research and development, as well as the preparation and packaging of our products, should: • know exactly the quality standards and procedures applicable to the products we produce; • follow all relevant control protocols; • comply with all applicable laws and regulations on food safety and environmental protection.
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Should you notice anything that might adversely affect the quality of our product, please contact the Head of the Food Safety Team, indicating your concerns.
Contact us for products We are proud of the high quality of the products we offer to the consumer and ensure proper and honest communication regarding their characteristics. Apart from meeting internal quality standards, our products must be produced, tested, packaged and labeled in full compliance with the applicable laws. The information labeled on the packaging of our products should be the same so that it is not misleading or incorrect. Proper communication is an important aspect of the company’s responsibility and influences the corporate image. For this reason, all our labels and our advertising are designed on the basis of national and EU provisions, while respecting strict ethical standards, in order to present a balanced version of the products, without exaggeration, misleading information or false statements. In addition, the company has a telephone line for clients’ and final consumers’ service, which is indicated on the labels of its products.
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Hellenic Dairies – Code of Conduct
Selection of partners We work with our partners towards achieving the goals that we set as a company, also ensuring the good reputation of Hellenic Dairies in the industry. For this reason we ask everyone who cooperates with us (suppliers, service providers, etc.) to respect our Code of Conduct, as well as the laws and regulations by which our operation is governed. We require all our partners, without exception, to be updated, accept and sign all the terms of the Code we have drafted, before starting any cooperation with them. Furthermore, Hellenic Dairies has adopted strict selection criteria for suppliers to ensure the provision of high-quality products and services, in order to always be in line with its own commitments for top quality products. Thus, in addition to the criteria relating to quality which are non-negotiable, the company has established criteria relating both to environmental performance and to the social face of its partners. Therefore, if we notice requests for advance payments that do not comply with signed contractual obligations, additional commissions, concealment of critical information, unusual transfers of money from countries with which we do not collaborate, we should highlight the matter by bringing it to the attention of the Internal Auditor or the Legal Department, reporting any immoral or inappropriate behavior or activity that comes to our attention.
Fair competition We respect our competitors and fully implement the applicable competition legislation, always acting responsibly.
Antitrust rules and laws are complex and numerous and their application may depend on various factors. It is better to be careful and ask questions rather than assuming that an action will be acceptable - bad judgment is not an excuse.
Hellenic Dairies, recognizing that free competition is a key element of the market as it promotes economic growth, efficiency and innovation, focuses on overcoming its competitors on legal and ethical grounds. Therefore, any uncompetitive practices are not compatible with our principles, laws and values, and may prove to be precarious regarding the image we want to preserve as a company. In addition, they may lead to sanctions that may harm Hellenic Dairies such as fines, civil liability for damage, exclusion from public procurement or even criminal prosecution. In general, information on pricing, clients, partners and competitors and any other relevant information (including third party copyrights such as know-how, patents) must be communicated/received only by legal means. Our behavior should also receive similar attention, as any defamatory statement against a competitor, defamation of their products or damage to their reputation is expressly prohibited.
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However, because there are many types of behavior that may be subject to antitrust laws, you must comply with these laws and if you have any questions or concerns, you should seek guidance from the legal department of the company.
Conflict of interest We are all required to make business decisions based on the interest of Hellenic Dairies and not based on our personal interests. A conflict of interest may arise when our personal interests affect or may be perceived as interfering with our ability to perform our work effectively and impartially. A conflict of interest may arise, inter alia, from secondary employment or equity participation of a competitor or business partner. We are not allowed to engage in any secondary employment which is contrary to the interests of Hellenic Dairies, especially if the employment in question is competitive with its activities. Business decisions concerning Hellenic Dairies should be made in a transparent manner, free of personal interests. Therefore, it is necessary to avoid any relationship or activity that could compromise, or even appear to affect, our ability to make objective and fair decisions when carrying out business activities on behalf of Hellenic Dairies. Such relationships include blood or marriage ties, cooperation with third parties or investments. Where such relationships or activities cannot be prevented or avoided, they should be directly reported. In addition, you should report to the manager any personal interest that might be perceived as related to the performance of your professional duties. In case of doubt, informing the manager is in your interest, as such an act often removes any suspicion of inappropriate activity.
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Hellenic Dairies – Code of Conduct
Gifts, hospitality and entertainment We always act according to the highest ethical standards. Hellenic Dairies does not offer nor accept gifts, hospitality and entertainment that may raise concerns about our integrity. Hellenic Dairies considers that corruption and bribery are bad practices, which can be detrimental to both the interests of the company and society in general. Having the possibility of healthy development in the societies in which we operate as our fundamental task, we deplore any incident that may be perceived as an act of corrupt behavior. Adhering to laws and setting an example for doing our business in an ethical manner is a way to implement this commitment in practice. Good business relationships are based on trust and goodwill and because we value and respect our clients and business partners, a party may want to recognize this by offering gifts and hospitality. However, note that when you offer or accept gifts, hospitality and entertainment in interactions with business partners, this can lead to a conflict of interest and be perceived as bribery or inappropriate advantage. In particular, the acceptance of gifts and tips (in any place, form or value) from clients, suppliers or external partners is prohibited, unless there is prior specific permission by the competent Head of the department. Also, the acceptance of personal invitations by partners or prospective partners of the company requires prior approval.
Question: When negotiating prices with one of our suppliers, he offered me a ticket to a football match that I would really like to watch. Is it acceptable to accept the ticket? Answer: No. Employees of Hellenic Dairies are not allowed to accept gifts or entertainment from any person or company during their participation in business negotiations, tender procedures and similar procedures. You should thank your supplier, but explain why you cannot accept his offer.
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Book and record keeping We keep up-to-date accounting books and accurate records of our business transactions which enable us to trace our activities. In all our transactions and in every form of communication we are accurate and sincere. This is the basis for how we deal with each other and what is expected from us in all our relationships with our clients, employees, investors and business partners, as well as with the public and all state agencies. No falsification or inappropriate alteration of documents and records is allowed.
The timely, complete and honest recording of financial and non-financial information and the proper preservation of our documents and records is essential for our company and is important for the following matters concerning us: • Reliability and reputation; • Legal and regulatory obligations; • The possibility of accurate forecasting and business decision-making; and • Responsibility towards shareholders and other external stakeholders.
Accurate business documents are necessary for the management of a successful company and are required by law. Each employee is responsible for ensuring that all company records, information and accounts are clear, honest and accurate. For example, expenditure reports, time records, payments and other transactions should, without exception, be correctly recorded (in a timely and comprehensible manner), accounted for and approved. For any transaction of value with a company, entity or person outside Hellenic Dairies, there should be a correct entry indicating the purpose, nature and participants in the transaction. Recordings which are incorrect, incomplete or modified do not reflect the true nature of the transactions, which is considered a fraud and is not acceptable by the company. If you have any questions about the company’s financial audits, accounting, financial reporting or audit, please contact the relevant department for clarifications.
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Hellenic Dairies – Code of Conduct
Principles governing our attitude towards the environment and society Human rights We respect and protect human rights throughout our business activities. This reflects the company’s support for both the UN objectives and the international conventions and principles contained in the United Nations Universal Declaration of Human Rights, the UN Convention on the Rights of the Child, the United Nations Global Compact and the International Labor Organization (ILO) Conventions and Recommendations. We prohibit the following practices in the course of our activities and will not engage in business deliberately with any person or company involved in the following: • Exploitation of children, including child labor • Corporal punishment • Violence against workers, of any kind • Forced or compulsory work • Illegal discrimination in employment and recruitment practices, including discrimination based on gender, origin, religion, sexual orientation, political beliefs or any other diversity parameter • Providing unsafe working conditions • Wage payments (or reductions) which place workers’ wages illegally below minimum wage. In case you have reason to believe that either within the company or one of our partners does not comply with applicable laws and regulations aimed at the protection of human rights, you are requested to share this matter with the staff department.
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Environment Environmental protection is our key commitment and is fully in line with the implementation of our corporate goals to achieve long-term sustainable growth. The protection of the environment and the conservation of natural resources are a top priority for Hellenic Dairies. Through the constant guidance and commitment of our employees, we make sure to conduct our activities in an environmentally safe way, aiming to continuously improve our environmental performance.
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Hellenic Dairies – Code of Conduct
For this reason, in addition to complying with environmental laws and norms or international standards, we often test our performance and develop policies/practices through which we aim at: • Saving energy and using renewable sources from self-generation • Reducing greenhouse gas emissions • Reducing and properly disposing of waste in the production process • Zeroing the organic load of waste generated at our facilities • Reducing the amount of water consumed through technologically advanced procedures and frequent checks for damage/leakage • Reducing the amount of plastic in product packaging • Evaluating the results of our processes to continuously improve the handling of our environmental impact • Updating and raising awareness among employees through specially designed seminars and trainings • Developing initiatives and organizing actions to protect the environment.
For more information on how to support this collective effort and contribute to meeting our objectives, please consult the Environmental Compliance Supervisor.
Sustainable development Our goal and aim is to achieve growth that meets current needs, without compromising the needs of future generations. The principle of sustainable development is a central choice and our goal. This is not only a means of expressing our corporate responsibility, but the basis on which decisions are taken. In this context, Hellenic Dairies operates in a stable and systematic way through: • The implementation of economic, environmental and socially beneficial methods and practices; • The use of methods and processes focusing on the conservation of natural resources and energy, the reduction of greenhouse gas emissions, optimal waste management and recycling; • Modernizing production methods and processes in accordance with the strictest European and international standards; • Training staff and assessing their compliance with the principles of sustainable development. Any employee, executive, member of the administration, subcontractor and, in general, any person who cooperates in any way with Hellenic Dairies shall respect and implement the principles of sustainable development by reporting to the competent authority any behavior that endangers the company, its business and social interests, as well as its ethical principles.
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Social participation and local communities We act as a responsible corporate citizen, making sure to contribute to the development of local communities and generate value for our social partners. Maximizing value for the social partners and harmonious coexistence with local communities are important parameters of the company’s social responsibility and the strengthening of its corporate image. Our aim is the mutual respect and trust relations with all actors in society, two characteristics which govern the decision-making process of the company in terms of its business, aiming at good cooperation and alleviation of any impact. Part of the company’s social responsibility is sponsorship and donations to institutions and organizations. This is an effort over time which evolves according to the conditions and aims to contribute to meeting any social needs, as the case may be.
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Hellenic Dairies – Code of Conduct
Clients and consumers We care for the impeccable service and continuous satisfaction of our clients and the supply of the market with innovative products that are characterized for their high quality and safety. Our main concern is to satisfy clients in the best possible way. We are making sure that we develop relationships of trust based on mutual respect and sincerity. Both our clients and consumers must be treated with the respect, responsibility and transparency attributable to every valuable partner, for all transactions between them and other issues that concern them. For this reason, all queries, requests and complaints that may arise from clients and final consumers are recorded and handled through the CRM system.
Communicating with the media Communication with the media should only be made by representatives of the company and in a specific way. We seek proper and focused communication and representation in the media on corporate issues to ensure business continuity. In this respect, you should not provide any information if you have been asked to discuss the company’s business with any press representatives, investors or market analysts. Instead, you should kindly inform that you are not authorized to discuss the matter and refer the person asking you the question to the relevant representative. Also, when using social media, you need to be clear that you are not speaking on behalf of the company. Only the management, or the competent department, shall be responsible for speaking on behalf of the company, unless the appropriate authorization has been given.
Question: I have received an invitation and I will attend a social event where a well-known journalist working in a local newspaper may also be present. If he asks me about new products we're about to launch, could I give him information so I can advertise the company at the same time? Answer: No. Τhe members of the administration, the competent department and those with such authorization are responsible for speaking on behalf of the company or about its products. This rule applies to all types of public communication and any media, including the internet and social media. Even a selfie or a video from the workplace could potentially disclose confidential corporate information.
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Advice and guidance on the implementation of the Code During your employment, you may face a situation that brings you to a moral dilemma, sooner or later. When this happens, do not hesitate to speak, ask questions about your responsibilities and report problems or a non-compliant behavior when needed. Try to resolve the questions or issues that concern you first with your manager or other relevant persons who can help, such as the Human Resources Department, the Legal Department or the Internal Audit Department.
When facing a moral dilemma, you should evaluate your choices by asking yourself the following questions: • Is it in line with the Code and how we operate? • Is it legal? • How will the rest react if they find out about my actions? • If I am not sure, have I asked for help or advice from a senior or the appropriate department of the company?
Protection against retaliation At Hellenic Dairies there will be no retaliation against any employee who reports an issue that concerns him/her in good faith. However, individuals who deliberately take action against an individual in the context of reporting an issue or taking part in an investigation will be subject to disciplinary sanctions that may go up to the end of cooperation.
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5th km of Trikala – Pili, Trikala, 421 00 www.hellenicdairies.com
