Scope & Objective
VIOPOL is committed to achieving the highest standards of ethical conduct and professional integrity and to ensure that the company acts in compliance with all applicable Greek Anti-Bribery laws.
The objective of VIOPOL’s anti-bribery policy is to create a corporate culture where every individual associated with VIOPOL, comprehends, and embraces their unequivocal obligation to abstain from all acts of bribery.
The policy will ensure that all stakeholders are well-informed about the prescribed course of actions and the appropriate person to report if there are any concerns pertaining to violations of anti-bribery regulations or criminal offences and will facilitate investigation of matters in instances where a ‘reasonable belief’ that there is unfair practice or may happen.
Definition of Bribery
- Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, or accepting an improper benefit, directly or indirectly with the intention on influencing or rewarding the behavior or the action of someone to obtain or retain a commercial advantage.
- Bribery can take a variety of forms – offering or giving money or anything else of value. In fact, even common business practices or social activities, such as the provision of gifts and hospitality, can constitute bribes in some circumstances.
- Bribery is illegal. Employees must not engage in any form of bribery, whether directly, passively (as described above), or through a third party (such as an agent or distributor). They must not accept briberies of any kind and if they are unsure whether something is a bribe or a gift or an act of hospitality, they should seek further advice from the officer in charge.
Types of Bribery
- Gifts, Hospitality and Entertainment
We are extremely careful with regards to giving and receiving gifts/meals and hospitality.
Gifts, hospitality, and entertainment must be modest, reasonable, and infrequent so far as any individual recipient is concerned.
Gifts, hospitality, and entertainment should never be offered or provided with the intention of influencing the recipient to take actions that benefit VIOPOL, to reward such actions, or to refrain them from taking actions that may disadvantage VIOPOL.
Do not cover the expenses related to the entertainment, hospitality, or travel costs of any accompanying individuals when inviting someone to a VIOPOL’s business meeting, conference, or similar event.
Before offering a gift or providing hospitality or entertainment to anyone, assess whether such actions could potentially harm the reputation of VIOPOL, yourself, or the recipient involved. If this could lead to any form of discomfort for either VIOPOL or the recipient, it is advisable not to proceed.
- Political Contributions
VIOPOL will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognize this may be perceived as an attempt to gain an improper business advantage.
- Charitable Contributions
VIOPOL supports and promotes charitable contributions in various forms, including but not limited to services, knowledge sharing, volunteering, and financial contributions. We commit to transparently disclose all our charitable contributions.
Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
We are obligated to ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the legal manager.
- Facilitation Payments and Kickbacks
VIOPOL categorically rejects and strictly prohibits any engagement in facilitation payments of any kind. We recognize that facilitation payments constitute a type of bribery aimed at expediting or facilitating the performance of a project.
We forbid the provision and acceptance of kickbacks. We recognize that kickbacks often involve offering benefits in exchange for business favors or advantages.
In case an individual may face a situation where refusing a facilitation payment or kickback may put their own or their family’s personal security at risk, and cannot, at that time, avoid the transaction, the following measures must be implemented:
- Keep any amount to the minimum
- Ask for a receipt that specifies both the payment amount and the purpose of the transaction if possible
- Create a record concerning the payment
- Report this incident to your immediate supervisor or the manager in charge of these incidents
Anti-Money Laundering
We actively comply with anti-money laundering and anti-terrorism laws and regulations. To this end, we do not accept cash payments and all payments are to be made by bank transfer. We keep accurate books and records and we prohibit any kind of falsification thereof. All of our books and accounting records may provide requisite information with supporting documentation for audits and investigations by the authorities in the event of a bribery incident.
Secret, unrecorded or unreported transactions are prohibited. All expenses must be accurately accounted for, include appropriate supporting documentation and be promptly entered into company records before they are reimbursed. Any and all transactions of our Organization are authorized by appropriate management in accordance with internal control procedures.
Reporting Mechanism
If an individual working for us or on our behalf, suspects that there is an instance of bribery or actions of corruption in relation to VIOPOL, she/he must raise concerns immediately. In the event of any uncertainties whether a certain action or behavior can be considered bribery, individuals must raise their concerns to their director, or the legal manager.
- Reporting Channel: Individuals that want to report an incident can send an email to the following email address: tharkoum@otenet.gr.
- Maintain confidentiality: Keep the incident confidential to protect yourself and the integrity of the investigation.
- Report the incident: Submit a detailed report of the bribery incident through email, providing all available information about the incident, including dates, individuals involved, and evidence.
- Protection from retaliation: Individuals who report potential misconduct in good faith or who provide information or otherwise assist in any inquiry or investigation of potential misconduct will be protected against retaliation.
- Investigation: Once the report is submitted, the organization or relevant authorities will initiate an investigation to assess the validity of the allegations.
- Cooperate with investigation: Τhe individual who made the report must cooperate fully with the investigation, providing any additional information or assistance required.
- Resolution: The investigation will lead to a determination of the incident’s validity. If bribery is confirmed, appropriate actions will be taken, which may include legal consequences, disciplinary measures, or corrective actions.
- Reporting to Authorities: If the bribery incident involves illegal activities, the organization may be required to report it to relevant law enforcement or regulatory authorities.
- Documentation: Maintain thorough records of the entire reporting and investigation process for compliance and documentation purposes.
- Continuous Monitoring: Continuously monitor and assess the effectiveness of anti-bribery measures to ensure ongoing compliance and prevention of future incidents. The Policy is being reviewed on an annual basis and refreshed or edited if necessary.
Implementation, Monitoring, Review & Update
VIOPOL will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy. VIOPOL’s Anti-bribery Policy will be clearly communicated to all suppliers, contractors, business partners and any third parties that may be engaged in business relations with VIOPOL. The Anti- Bribery Policy is displayed at the official Company website.
| About the Policy | Policy Contact: |
| Effective Date: | Mr. Touloumis G. |
| Title : Production & Plant Operations Manager | |
| Tel: +30 22620 56201, +30 6947 429747 | |
| email: george.touloumis@viopol.com | |
| Date of Last Review/Update: | Policy Feedback: |
| 18.12.2023 | In case of comments or questions, let us know via email at info@viopol.com |
