Whistleblowing Policy

Α. Introduction
The purpose of the Company’s Whistleblowing and Reporting Policy is to establish a framework for the timely detection of irregularities, omissions, or criminal acts within the Company’s operations and to protect individuals who report such violations, in accordance with the provisions of Law 4990/2022. Accordingly, a core and non-negotiable principle of this policy is the protection of anonymity and confidentiality of the individuals who submit such reports or complaints.
Whistleblowing refers to the intentional act of disclosing (reporting or submitting a complaint) incidents that are recorded in the Company’s files and submitted by a person who becomes aware of significant irregularities, omissions, or other actual, potential, or expected criminal activities within the Company and communicates them to a responsible person in order to initiate corrective action.
Reports are submitted without any expectation of reward and are based on the principles of transparency, accountability, and integrity. They serve to protect the reputation and assets of the Company, its shareholders, and its clients from unlawful acts by its personnel and executives that may harm its credibility and public image.

Β. Scope – Exceptions
Reportable incidents may include, but are not limited to:

• Theft
• Fraud
• Corruption
• Bribery
• Intimidation
• Misconduct
• Any form of harassment (e.g. sexual harassment)
• Abuse of authority
• Undue influence
• Misuse of company assets
• Breach of banking secrecy
• Misrepresentation of data
• Violation of Company policies
• Violation of applicable legal and regulatory frameworks
• Any other ethically inappropriate behavior

This Policy applies to the Company and its subsidiaries and specifically to:

1. Employees, regardless of full-time, part-time, permanent, or temporary employment status, or form of employment relationship.
2. Non-salaried workers, external partners, freelancers, or consultant.
3. Shareholders and members of the Board of Directors, including non-executive members and members of Board Committees.
4. Individuals working under the supervision of contractors, subcontractors, and suppliers.
5. Individuals reporting violations discovered in the course of an employment relationship that has ended (e.g. retirees), or prior to its commencement (e.g. during the hiring process).
6. Intermediaries
7. Third parties associated with whistleblowers (e.g. colleagues or family members).
8. Entities owned or represented by whistleblowers or where they are employed.

C. Whistleblowing Officer (WBO)
The Company and its subsidiaries appoint a Whistleblowing Officer (hereinafter “WBO”) to receive and monitor reports that fall within the scope of this Policy. The WBO is the Company’s Compliance Officer.

The WBO’s term lasts at least one (1) calendar year but may end earlier for just cause.

The WBO may be either an internal employee or an external party who complies with the requirements of this Policy. In both cases, the WBO reports directly to the Company’s CEO.

The WBO must:

a) Maintain confidentiality and discretion regarding all information obtained during the performance of duties,

b) Act with integrity, objectivity, impartiality, transparency, and social responsibility,

c) Recuse themselves in cases of potential conflict of interest.

The WBO cannot be someone:

a) Facing criminal prosecution or convicted for offenses such as theft, fraud, corruption, embezzlement, bribery, defamation, breach of duty, or crimes involving public office, sexual misconduct, drug or gambling offenses

b) Who has been subject to disciplinary actions resulting in permanent dismissal or severe penalties

c) Who is under suspension or restriction of duties

The appointment of a WBO does not preclude direct reporting to the National Transparency Authority (NTA) if the whistleblower reasonably believes the matter cannot be effectively handled internally or fears retaliation.

Responsibilities of the WBO:

a) Provide clear information regarding internal reporting channels,

b) Receive reports and confirm their receipt within seven (7) working days,

c) Initiate internal investigations or dismiss reports that are vague, baseless, or fall outside the policy’s scope,

d) Protect the confidentiality of the whistleblower’s identity and any third parties named in the report,

e) Maintain communication with the whistleblower, requesting additional information as needed,

f) Provide updates on the case status within three (3) months of confirmation of receipt,

g) Share accessible information about external reporting options (e.g. NTA, public authorities, EU institutions),

h) Coordinate awareness and training programs on ethics and integrity

If the WBO performs additional roles, these must not compromise their independence or create conflicts of interest.

D. Reporting Procedure
The Company encourages employees to first raise concerns with their direct supervisor for internal resolution. Alternatively, employees are expected to report serious incidents of misconduct via post, telephone, or email. Anonymous reports are also accepted, especially where concerns over retaliation exist.

Reports are evaluated by the Compliance Officer. If in doubt, or if clarification is needed regarding protection or procedure, inquiries may be directed to the Company’s HR department.

Reports must be made in good faith. Information provided will be handled confidentially and assessed by trained personnel with a duty of confidentiality. The reporting process must not be misused for baseless accusations or personal grievances.

Ε. Confidentiality / Anonymity
The Company encourages named reporting, as anonymous reports may hinder thorough investigation due to difficulties in follow-up and credibility assessment. Anonymous reports will be evaluated based on the degree of substantiation and ability to identify the alleged wrongdoing.
The Company commits to maintaining the whistleblower’s anonymity and will not take actions that could lead to disclosure of their identity, except where required by legal proceedings. In such cases, the anonymity of others named in the report will still be protected.
All processing of personal data will be carried out in accordance with applicable data protection legislation.

F. Protection Against Retaliation
The Company commits to protecting all individuals within the scope of this Policy who, in good faith, submit a report or complaint from any form of retaliation, now or in the future.

All forms of retaliation are strictly prohibited, including threats or acts of retribution.

Specifically prohibited forms of retaliation include:  a) Dismissal, termination, or similar measures,

b) Demotion, denial of promotion,

c) Reduction of duties or salary, workplace reassignment,  d) Denial of training,

e) Negative performance evaluations,

f) Disciplinary actions or financial penalties,  g) Harassment, marginalization, or bullying,

h) Discriminatory treatment,

i) Failure to convert temporary contracts to permanent,

j) Premature contract termination,  j1) Damage to reputation (e.g. on social media), financial harm,  j2) Blacklisting in the sector, j3) Cancellation of service or product contracts, j4) Revocation of licenses or certifications,  j5) Forced psychiatric or medical evaluation,  ιστ) Denial of reasonable accommodations for disabilities.

Whistleblowers who act in accordance with legal provisions shall not suffer negative consequences. However, false or malicious claims may lead to sanctions as provided by law.

If a whistleblower is implicated in the wrongdoing, their cooperation will be taken into account but will not exempt them from responsibility.