качество - ΑΛΜΗ ΑΒΕΕ | Ορεκτικά Ελληνικής Φύσης

STATEMENT AGAINST BRIBERY AND CORRUPTION

Bribery and corruption in general in all its manifestations is one of the most serious and difficult issues to manage, which dogs today’s entrepreneurial activity internationally. Our company has a zero-tolerance policy towards bribery, the receiving of bribes and cases of corruption generally. We operate all our professional transactions with transparency, integrity, professionalism and apply corporate ethics. The company applies and complies fully with Greek legislation, and specifically with the provisions of the Hellenic Criminal Code (articles 236, 237, 237A, 237B, 238, 263Aand 263B), laws 2656/1998, 2802/2000, 2803/2000, 2957/2001, 3560/2007 and 3666/2008, as amended by Law 4254/2014, as well the Conventions and Rules of the United Nations. ALMH ABEE, apart from complying faithfully with the law, recognising the importance of fighting bribery and corruption and being cognizant of the negative consequences any involvement the company might have with bribery, has introduced and applies an Anti-bribery policy. This Policy operates supplementary to the Ethics Code, aiming to raise the awareness of all its employees and partners in order to fight bribery.

WHAT CONSTITUTES BRIBERY?

Anyone who works or provides services in any capacity or relationship with our company, who, during the exercise of their company activity, asks for or receives, directly or indirectly, any kind of benefit for themselves or another, or receives a promise of such a benefit in exchange for some act or failure to carry out some act in violation of their duties, as set out in law, the labour contract, the internal regulations, the orders and instructions of their superiors or which derives from the nature of their post or services.

WHO DOES THIS ALMI ABEE POLICY APPLY TO?

Our company policy against bribery does not discriminate depending on the person who commits the illegal act, but applies to all persons, irrespective of the post or rank they hold, including senior management staff, senior employees, directors, employees (on a fixed term or open-ended contract), consultants, trainees, supplementary employees and any other persons connected with ALMI ABEE. Furthermore, a ‘third’ part denotes any natural person or employee of an organisation who, during the exercise of their duties comes into contact with ALMI ABEE and includes actual and potential customers, consumers, suppliers, distributors, as well as government and public organisations and their advisers, representatives and employees.

LEGAL PROCEDURES TO COMBAT BRIBERY AND CORRUPTION

Should it be brought to the attention of a member of our company that an employee or external partner displays criminal behaviour then the former may file a complaint regarding the incident with the relevant company section. After this, the complaint, together with all the necessary facts which should accompany it, is evaluated and checked by the company’s legal department to ascertain whether it is indictable and that legal action can proceed. The legal actions the company pursues through its specially authorised persons are, in detail:

Filing a lawsuit before the local competent Prosecutor, in cooperation with the Authorities, by furnishing any information deemed necessary.
Filing a claim for compensation against the perpetrator of the unlawful act for full compensation for losses, which may cover positive damage, lost profit and non-pecuniary damage.
Filing a claim for cancellation of the contract, whose object results from corruption or is the product of a declaration of intent of the party which had been influenced by a corrupt act.

WRITTEN PROTECTION FOR THOSE REPORTING THE ILLEGAL ACT

ALMI ABEE places great value on clear and open communication and would not carry out reprisals against anyone who reports cases of corruption (suspicious behaviour) or infringement of the Policy against Bribery. Every employee or business partner may report such issues without fear of dismissal, adverse change in situation or reprisals of any kind. Our company forbids every type of negative/intimidating conduct exercised to the detriment of an employee who has made a report, even if the report is proven to be incorrect. More specifically, they are bound to refrain from belittling, threatening, harassing or in any way discriminating against any employee as a result of the report. Our Company respects Greek legislation and specifically Article 9 of Law 2957/2007, (ratification of the convention of the Council of Europe on subjects of civil law on corruption) as well as the special provision of Article 263B of the Criminal Code. In particular, apart from respecting the laws, to protect those who report on illegal actions, our company:

Appoints a person to receive all complaints, and who is responsible for collecting evidence for the investigation and also for emails lodging complaints, and who may be approached by someone who has become aware of an illicit action.
Appoints a second person as a recipient of complaints in the case that the complainant wishes to file a complaint against the responsible person him/herself.
Provides a specific report form which is filled in by the complainant with the name concealed.

WRITTEN CORRECTIVE PROCEDURES (DISCIPLINARY PROCEDURES) FOR OFFENDERS

Beyond the criminal penalties imposed under Greek law with the issuance of an irrevocable decision of the competent courts, our company will terminate the existing contract for dependent work with the offender if it is ascertained that an employee of the company has engaged in illegal actions related to bribery, receiving bribes, abuse of power, money laundering and offences related to corruption in general either within the company’s premises or outside them. If an external partner or supplier is the guilty party, the existing contract will be terminated and all cooperation with them will cease.

GIFTS AND HOSPITALITY

ALMI ABEE recognises that in many places, the offer of gifts is considered as a customary way to seal closer personal ties or as a mark of gratitude for services provided. Nevertheless, in accordance with its Policy, ALMI ABEE is particularly cautious regarding offers of or receiving of gifts; while customary gifts are usually considered acceptable, those which are seen as excessive, luxurious or in any other way inappropriate, are not to be offered or accepted. In any case, the intention behind the offer of a gift will be taken into consideration. Under no circumstances will cash or other similar gifts be accepted. Each company employee who intends to offer a symbolic gift, including that for hospitality, should complete the printed application-declaration form for approval by the head of the economic department.

ALMI ABEE’S POLICY ON CHILD LABOUR

On the subject of child labour, our company operates and acts applying Greek and European legislation to the full. Specifically, our company acts according to Law 1837/1989, the International Labour Convention (No 138), which was ratified by Greece under Law 1182/1981, the International Labour Convention (no 182) regarding the prohibition of the worst forms of child labour and direct action for its elimination, which was ratified by Greece under Law 2918/2001, as well as according to the International Convention for the Rights of the Child, which was ratified by Greece under Law 2101/1992, as well as completely respecting and meeting the principles of the BSCI Code of Conduct. Our company has never employed a minor and has never been condemned for a similar offence.

Our choice of partners is made with respect to and in application of Greek and European legislation. Should a member of our company becomes aware that a partner of ours is employing a child/children under the age of 15 in violation of the aforementioned laws and European conventions, our company, through its legal representatives, or specially authorised persons, shall file an official complaint to the local competent Hellenic Labour Inspectorate, which is institutionally empowered to start legal proceedings. In this case, our company, through its representatives, shall attend the hearing as the witness for the prosecution.

ΑIf a member of our company becomes aware that a partner or supplier of ours is employing in their company a child under the age of 15 and does not meet the conditions set out in the aforementioned laws and that there is evidence of exploitation of the child worker, particularly with regard to working conditions, then our company, through its legal representatives or specially authorised persons shall file an official complaint to the local competent Hellenic Labour Inspectorate, which will conduct those actions required by law.

BEYOND THE LEGAL MEANS HOW ELSE DOES THE COMPANY ACT?

All employees are always hired by the company through the furnishing of official public documents which indicate the age of the employees.
Cooperation with any offender is terminated.
Up until 30/06/2019, all external partners/suppliers will have signed a document in which they pledge to respect apart from ALMI ABEE’s Code of Conduct, the principles of BSCI and shall act in compliance with those.
If the external partners fail to sign the aforementioned documents and they do not comply with the company’s principles or with those of BSCI, our cooperation is terminated.
To check the maintaining of the above agreements, our company shall carry out unannounced and on-the-spot checks on the partners’ premises, at the responsibility of those responsible for its respective departments

Alexandria, 13 September 2018

ALMI ABEE