CODE OF CONDUCT

What is the Code of Conduct?

The Code of Conduct reflects the general principles that determine the employees’ responsible business conduct and the rules of ethics that all its employees and partners of VIOPOL are expected to follow, as well as the commitments of the Company’s Management towards its people.

The Code of Conduct of VIOPOL ensures that all Company activities are conducted with integrity protecting its reputation.

The content of the Code includes rules of acceptable employee behavior against third parties, natural or legal, of private or public law, of the country or foreign, while exceeding compliance with the laws in all areas of the Company’s activity, demonstrating their commitment to operating with integrity in each case.

 

To whom is the Code addressed?

• The Code addresses, concerns and binds both the already employed, as well as the newly hired, who, upon recruitment, fall automatically under the Code.
• It addresses, concerns and binds the partners and consultants they represent or operate on behalf of the Company, or through outsourcing services or any other business activity.

 

VIOPOL’s vision
«Η εικόνα μας κερδίζει»

VIOPOL’s mission
Creating PURe Value for all the company’s stakeholders.

 
VIOPOL’s values

• Respect
• Consistency
• Confidence
• Responsibility
• Creativity
• Orderliness
• Continuous improvement & development
• Sustainability

 
 
Healthy and Safe Occupational Environment

It is our belief that a safe and healthy working environment is vital for our efficiency and for the sustainable development of our company, as it has an impact in our personal lives and in the communities we operate. We nurture therefore a preventative safety and health culture into every aspect of our daily business.
Our company is in compliance with all applicable laws and regulations concerning occupational health and safety and has adopted a safety and health policy laid down upon the highest industry standards. An internal audit system is applied to insure we meet the requirements of standard ISO 45001 for occupational health and safety management.

It is though our responsibility:

• to read, understand and follow all the safety and health rules set out by our policy and the applicable laws and regulations.
• to recognize and report any actual or potential risk or near miss incident at work.
• to read and understand our company’s emergency plan and preserve the emergency equipment.
• to ensure that our working environment does not affect our mental and physical health and our well-being.
• to ensure that we are able to perform assigned duties safely and effectively without any limitations due to the use and or after‐effects of drugs and alcohol, or any other substance that can negatively impact being fit for work.
• to report any concerns and to identify areas (such as non-safe work conditions and behaviors) in need of improvement regarding health and safety.
• to participate in training and information programmes organised by VIOPOL regarding Safety issues

We should all be committed to preventing injury and illness and fostering psychological and physical health and wellbeing for all our people.

 

Environmental responsibility
 
Protecting human health, natural resources and the global environment is one of our main commitments. VIOPOL implements environmentally sound practices including stringent measures for process safety, to reduce its environmental impact deriving from its business activities and ensure the protection of its employees.
Our business operations are conducted in accordance with all environmental laws and regulations, including obtaining and maintaining all the required permits and approvals. Further than that we have established an internal audit system insuring that we meet the requirements of standard ISO 14001  for environmental management.
Our culture of environmental stewardship permeates our business from sourcing of raw materials to waste management. We are committed to reducing waste and pollutants, conserving resources, and recycling materials at every stage of the product life cycle.

It is our responsibility:

• to acquaint ourselves with the environmental requirements of our work as laid down by our environmental policy and the applicable laws.
• to identify the environmental risks and hazards in our work and to understand the preventive actions to be taken to eliminate or reduce them.
• to use energy, water and other resources efficiently.
• to follow all the applicable regulations for use, storage, labeling, transport and disposal of chemicals.
• To look for business partners who have the same environmental culture as we do.

Caring about the environment is vital for the endurance of the community we serve, the longevity of our company and our future success.

 

Customer and product quality and safety 
 
Our business success is owed to the fact that both customer’s needs, and product safety and quality are our uncompromising priorities.  We are committed to delivering   sustainable and high-quality solutions to our customers and to marketing products that have proven efficacy and safety.
We apply strict safety and quality controls at every stage, from the selection of raw materials to manufacturing and distribution process. Our products quality and safety are always controlled and approved following the applicable procedures provided by law and regulations.

We should:

• listen to our customers’ business needs and requirements to meet their expectations.
• listen our customers’ concerns about the efficacy and the safety of our products.
• we monitor all of the available scientific information and new technologies relating to our products, to enhance the efficacy and the safety of our products.

The quality and the safety of our products allows us to build continuous relations of trust with our customers.

 

Human Rights – Fair Working conditions
 
Our company respects and upholds applicable Laws and Regulations pertaining to human rights, human dignity, and labor practices. In particular:

• we will not tolerate child labor or forced labor in our own operations or those of our business partners.
• We ensure that working hours and overtime work are in compliance with national laws and industry standards.
• We will pay wages and provide benefits as provided by the national law and in proportion with the local market conditions.
• We respect our employees’ right to freedom of association and collective bargaining.
• We have the right to be treated with respect and not be subjected to physical, verbal or financial punishment.

Further than that, our company is committed to offering equal opportunities regardless of race gender, nationality, age, sexual identity, or political opinion or any other characteristic.

• Everyone of us should be treated in a fair and respectful way.
• All employment and business decisions should be objective and based on professional criteria.
• We do not permit any form of intimidating or disrespectful behavior, bullying, sexual harassment or unlawful discrimination.

A fair and inclusive occupational environment contributes at our mental well-being, increases our engagement, and improves our performance.

 

Fair competition
 
Our success is driven by our people, our products’ quality and the trust relations with our clients. We compete vigorously and ethically in the limits set out by antitrust and fair competition laws. We will never enter in any type of official or unofficial agreement that results or appears to result in manipulating or distorting the free competition.

For this purpose:

• We do not make any arrangements with competitors that could restrict competition by fixing prices, sharing markets or rigging bids.
• We shall never exchange sensitive information with competitors such as prices, discounts and customers’ business.
• It is strictly forbidden to obtain sensitive information on competitors from customers, suppliers or any other business partners, unless this information is public.
• We are mindful that face to face discussion has the same evidential value as emails, formal letters, and written agreements. Therefore, if we find ourselves in a discussion on competitively sensitive issues, we immediately leave and report the incident to our manager.
• We present our values with honesty and accuracy and we never denigrate our competitors. Additionally, we will never incite our customers or business partners to breach their contracts with our competitors.
• We always contact company’s legal team if we have become aware or suspect that competition law has been breached or if we are exposed to competition law risks (ex. industry associations, meet competitors).
• We must not abuse any dominant market position in any country we operate
• We are prohibited from obtaining information about the competition through industrial espionage, bribery of third parties, fraud, electronic theft or pressure on third parties to disclose prices

It is our belief that healthy competition is essential for the longevity of our company as it offers an incentive to excel, to foster innovation and diversity of supply.

 

Dealing with Suppliers
 
We select our suppliers based on objective criteria such as our needs, safety, quality, availability, cost, compliance with the key principles of sustainable development and in particular with specific environmental and social criteria, and supplier experience and integrity. We offer equal opportunities to all existing or candidate suppliers. We expect our suppliers to comply with national and international rules and embrace and practice the same values and principles as we do.

For this purpose:

• We select our supplier carefully and we shall have with them written agreements with explicit purchasing terms.
• We cooperate with and we support our suppliers to achieve improvements and meet customers’ changing needs.
• We pay suppliers according to the agreed terms, unless there are legitimate reasons for not doing so, such as merchandise ordered are defective.
• We expect that our suppliers will keep confidential all our information and we protect the suppliers’ confidential information as if it were our own.
• We conduct our own quality tests for products to be purchased even if the supplier assumes full product responsibility.
• Our suppliers should be familiar with the “Suppliers Code of Conduct” of VIOPOL which can be found in the Company’s webpage
• It goes without saying that VIOPOL shall terminate any business relation with a supplier or contractor who is found to apply unlawful practices.

Building a reliable, dynamic, and agile supplier base is crucial for our company and our long-term success.

 

Bribery, Corruption, laundering money

We are committed to conducting our businesses in a fair, honest and ethical manner, and we have no tolerance to bribery and corruption in every country we operate.

More specifically:

1. a) bribery is the offering, giving, receiving, or soliciting of something of

value in order to securing a business advantage.

1. b) Corruption is the abuse of entrusted power for private gain.
2. c) Money laundering is the illegal process of making large amounts of money generated by criminal activity (drugs, terrorism etc.), appear to have come from a legitimate source through legitimate businesses

All the above situations are forbidden within our company and our partners are expected to have the same attitude towards these matters as we have.

For this purpose:

• We do not offer, accept, request or authorize gifts, payments or other advantages that could or appear to influence a business decision or raise questions about our integrity.
• We do not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates.
• We forbid the provision and acceptance of kickbacks
• We make reasonable efforts to ensure our business partners’ integrity and legitimacy in their commercial activities.

As VIOPOL uses many third parties such as consultants the employees tasked with this selection should:
– Select third parties after due diligence of their integrity.
– Ensure they are bonded by appropriate contractual terms against bribery and corruption.
– Ensure that they understand the requirements and that they comply with the Code
– Continuously updated and control those partners

Any infringement of the antibribery and anticorruption laws, that can have very serious consequences, (pecuniary and penal sanctions) will disturb our concentration to our business goals of long-term success and viability and will harm our company’s reputation. Therefore, we shall protect us from such behaviors.

 

International trade

Our company’s activity has been expanded with success to many countries around the world. International trade however is regulated by customs, export control economic sanctions laws with which we shall comply. International trade requirements or prohibition are stipulated by product/service, use, country or region and individuals.

When conducting our activity abroad, it is our responsibility:

• to have an evidence-based knowledge about the product, its ingredients and its origin.
• to know the applicable legislation at the country of the product’s origin and at the country of product’s destination.
• to have an evidence-based knowledge about the identity of our business partner and the end user and to ensure that transactions with them are not prohibited.
• to know the end-use of the product.
• to issue any required export license or other authorization before performing the contract.

Failure to comply with the international trade and economic sanctions laws can have serious consequences for our company and can harm our reputation as a responsible business partner.

 

Accurate business records 
 
We believe that keeping complete and accurate business records is of paramount importance for our company. It ensures and documents our compliance with applicable laws, regulations and rules and it is key for the efficient management of our company.

It is our responsibility:

• To keep detailed business records accurately and in such way that each transaction can be identified and documented as a whole.
• To protect the integrity of our records, and maintain them securely.
• To endure that the records are kept according to our policy and in a way that our deputy can easily continue.

Our business records reflect our financial health and our responsibility. Therefore, we insure we keep them on time, with accuracy and honesty.

 

Company assets – confidential information
 
Our company’s assets are consistent of both tangible (premises, equipment, devises, computer hardware and software, furniture, etc.) and intangible (trade secrets, trademarks, intellectual property, information, etc.) assets. These resources are intended to be used for the achievement of our company’s business goals.

It is our responsibility:

• To use our company’s assets responsibly and efficiently.
• To protect company’s assets from loss, damage, waste, misuse and unauthorized access.
• To keep confidential all information gained during our employment, concerning our company, our employees, our business partners and our stakeholders. This commitment to protect confidential information continues even if we leave the company.

Any loss, harm or misuse of our company’s assets can disturb our operations. Therefore, we should protect our company’s resources.

 

Conflict of interest

A conflict of interest is a situation in which our personal interests are inconsistent with those of our company. The term personal interest also includes the interest of our relatives or close associates. In such cases, our business actions and decisions may be affected and considered to be in conflict with our company’s interests.

Τo avoid harming our company’s interests, we are responsible to:

• To take business decisions objectively and in the best interest of our company.
• They are obliged to avoid making unfair use of their position in the Company for the benefit of their relatives or close associates.
• To know that situations such as secondary occupation, shareholding or being a member of BoD or an advisor in competitors or business partners may give rise to a conflict of interest with our company.

Given that providing, for the purposes of the present document, an exhaustive list of all cases where a conflict of interest may arise is not possible, the VIOPOL’s employees are advised to consult xxxxx if in the performance of their duties they are required to act in a way which deviates from the established one and are unsure as to whether such action gives rise to conflict of interests, so that they may obtain suitable guidance for working out an appropriate solution.

 

Reporting misconduct

This Code is applicable to all of us and ensures that we operate in an ethical way to attain our goal for sustainable development. Any violation of this Code and the relevant laws may lead to pecuniary or penal sanction and harm our company’s reputation.

In case of violations of the Code, VIOPOL will carefully investigate the relevant reports, while maintaining the confidentiality of the information, unless provided for by of the law something different.

The company will evaluate our report and an internal investigation will be conducted if necessary. The information we provide is kept confidential.

The Company’s Management ensures that no action will be taken against any employee who reports, in good faith, any actual or alleged impropriety behavior.

The reporting process should not be misused for reckless accusations or personal complaints. For prevent malicious or unfounded reports, sanctions may be imposed on employees who have acted in bad faith.
 
 
 
Validity and distribution of the Code

The present Code was formed in November 2023. It will be revised yearly.
The Code is available to all VIOPOL employees including the Board of Directors.
Apart from the internal promotion procedures of the Code applied by the Company, employees can obtain it either in printed form addressed to the Human Resources, or electronically from the Company website.

The Code is explicitly notified to all young employees when they join the Company by their respective manager.

 

Personal Commitment and Acceptance of Code

I herewith certify that I have received a copy of the Code of Conduct
of VIOPOL, that I have read it, that I understood it and that I will abide by it.

If I become aware that there has been a potential breach of the Code,
I will report the offense explained at Reporting misconduct section.

 

Date :

Employee’s signature:

Name of the employee:

About the Code of Conduct	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:
	In case of comments or questions, let us know via email at info@viopol.com