Prevention and Response to Bribery in the Workplace
This Policy reinforces the Management’s commitment to zero tolerance towards bribery, establishing a framework of obligations and guidelines to serve as a tool for preventing, deterring, and combating bribery. In this context, it meets the requirements of the anti-bribery management system according to ISO 37001:2025 and aims at the continuous improvement of the system, suitable for the company’s purpose and activities. Bribery is any payment or offer of payment of value to any public official or other person in the private or commercial sector, intended to induce the recipient to misuse their position and gain an unfair business advantage.
Note: Both the giver and the receiver of a bribe are considered equally culpable.
All persons and businesses covered by this policy must know, understand and comply with the contents of this Policy. It is posted on the company’s website so that all interested parties can take note of it. It will also be communicated to employees upon hiring and to partners – suppliers and subcontractors upon commencement of cooperation.
This Policy applies to:
- Employees of the company, including board members;
- Subcontractors, suppliers, and all forms of business partners acting on behalf of the company.
The Policy aims to:
- Ensure compliance with applicable anti-bribery laws and regulations
- Promote understanding of the definition of bribery;
- Encourage confidential reporting of any incidents or suspicions of bribery through the company’s established procedures and policies;
- Heighten awareness among employees and partners to recognize actions related to bribery;
- Protect the company’s reputation.
Reporting Suspected Violations
If you have doubts about how to respond to a situation or whether certain behavior may be inappropriate or contrary to this Policy, you should seek guidance and advice from the anti-bribery compliance team or the company’s legal partners. You can submit your inquiries to the email address: mavridou@truework.gr .If you identify non-compliance with the Policy or anti-bribery legislation, you should report it, either anonymously or with your identity, to the anti-bribery compliance department. The company encourages the submission of responsible, good-faith, and professionally conscious reports.
Reports can be submitted:
- By physical mail, addressed to the Anti-Bribery Compliance Officer, at: Lykaonias 2 & Eastern Thrace, Evosmos, P.C. 56224;
- By email to: mavridou@truework.gr
- By phone: +30 2310 517 176, requesting a member of the anti-bribery compliance team.
The company commits to evaluating all reports received through the above channels regarding their accuracy and significance, to determine whether there are substantial reasons necessitating an investigation. Reports and evidence are kept by the anti-bribery compliance team. The company is committed to protecting the anonymity of individuals who submit such reports and the confidentiality of the information they contain.
Violations and Sanctions
Any employee or partner of the company who violates this Policy may be subject to disciplinary measures, which may include penalties. Disciplinary penalties are decided individually in each case, depending on the nature and severity of the demonstrated behavior and the identified violation, and are imposed subject to the provisions of applicable law.
Protection Against Retaliation
The company will not retaliate against anyone who reports bribery incidents (suspected behavior) or violations of the Anti-Bribery Policy. The company prohibits any negative behavior towards an employee who has made a report, even if the report proves to be false. Specifically, the company will not demote or dismiss any employee due to their report. It will also not tolerate any retaliation or harmful treatment of an employee or partner as a result of their refusal to engage in bribery. The Anti-Bribery Policy is approved by the company’s representative, reviewed annually, and revised when necessary. The responsibility for preparing the revisions lies with the anti-bribery compliance team. The company ensures the conduct of training to understand the content and raise awareness among employees on bribery issues.
