Policies and Practices - eltrak
Tax Evasion Policy
Tax Evasion Policy Policy Statement

It is our policy to conduct all our business in an honest and ethical manner. The Company takes a zero-tolerance approach to facilitation of tax evasion under Greek law or under the law of any foreign country.

We are committed to acting professionally fairly and with integrity in all our business dealings and relationships wherever we operate and to implementing and enforcing effective systems to counter tax evasion facilitation.

The Company will uphold all laws relevant to countering tax evasion in all jurisdictions in which we operate.

About This Policy

The purpose of this policy is to:

a) Set out our responsibilities and the responsibilities of those working for us, in observing and upholding our position on preventing the criminal facilitation of tax evasion; and

b) Provide information and guidance to those working for us on how to recognise and avoid tax evasion.

As an employer, if we fail to prevent our employees, workers, agents or service providers facilitating tax evasion we can face sanctions including fines.

The Group has identified that the following are particular risks to the business:

a) Work status of contractors.

b) Tax status of third parties / suppliers.

c) Sub-contractors.

d) Countries where business is performed; and

e) Change in invoice details – bank account, dates of service, company name.

To address these risks our management ensures that any identified risks and procedures to mitigate against the same are communicated down the business chain to relevant third parties to ensure that they are embedded and understood. Additionally, our management require our staff those in our business chain and other relevant third parties to review, understand and provide signatures demonstrating their understanding of this and other relevant policies.

In this policy third party means any individual or organisation with whom you come into contact during the course of your work for the Company and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers and government and public bodies, including their advisers, representatives and officials, politicians and political parties.

Who Must Comply With The Policy?

The policy applies to all persons working for the Company or any Subsidiary Companies on our behalf in any capacity including employees of all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners, sponsors, or any other person associated with us wherever they are located.

Who Is Responsible For The Policy ?

The Board of Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it.

The Compliance team, , has primary and day-to-day responsibility for implementing this policy monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in preventing the facilitation of tax evasion.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

What Is Tax Evasion Facilitation?

For the purpose of this policy:

a) Tax evasion means the offence of deliberately and methodically avoidance of the proper payment of the taxes as specified in the Greek law.

b) Foreign tax evasion means evading tax in a foreign country, provided that the conduct is an offence in that country and would be a criminal offence if committed in Greece.

c) Tax evasion facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether greek tax or tax in a foreign country) by another person or aiding, abetting, counselling or procuring the commission of that offence. Tax evasion facilitation is a criminal offence where it is done deliberately.

Tax evasion is not the same as tax avoidance or tax planning. Tax avoidance sometimes qualifies as tax evasion and administrative and criminal offence Τhe Anti-Tax Avoidance directive includes specific measures for the aggressive tax planning and a general anti-abuse rule to counteract aggressive tax planning when other rules don’t apply. Tax avoidance is not always illegal when involves taking non-abusive steps within the law to minimise tax payable.

What You Must Not Do

It is not acceptable for you (or someone else acting on your behalf) to:

a) Engage in any form of facilitating tax evasion or foreign tax evasion.

b) Aid, abet, counsel or procure the commission of a tax evasion offence or foreign tax evasion offence by another person.

c) Fail to promptly report any request or demand from any third party to facilitate the evasion of tax (whether Greek tax or tax in a foreign country) or any suspected evasion of tax (whether Greek tax or tax in a foreign country) by another person n accordance with this policy.

d) Engage in any other activity that might lead to a breach of this policy; or

e) Threaten or retaliate against another individual who has refused to commit a tax evasion offence or a foreign tax evasion offence or who has raised concerns under this policy.

Your Responsibilities

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of tax evasion and foreign tax evasion are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if an employee or supplier asks to be paid into an offshore bank account, without good reason, or a supplier asks to be paid in cash, indicating that this will mean the payment is not subject to applicable tax. Further “red flags” that may indicate potential tax evasion are set out in Potential Risk Scenarios: “Red Flags”.

How to Raise a Concern

You are encouraged to raise concerns about any issue or suspicion of tax evasion or foreign tax evasion at the earliest possible stage.

If you become aware of any evasion of tax (whether Greek tax or tax in a foreign country) by another person in the course of your work, or you are asked to assist another person in their evasion of tax (whether directly or indirectly) or if you believe or suspect that any fraudulent evasion of tax has occurred or may occur, whether in respect to Greece or tax in a foreign country, you must notify your manager as soon as possible.

If you are unsure about whether or not a particular act constitutes tax evasion, or foreign tax evasion, raise it with your manager as soon as possible. A deliberate failure to report suspected tax evasion or foreign tax evasion or “turning a blind eye” to suspicious activity, could be equivalent to criminal facilitation of tax evasion.


Individuals who raise concerns or report another’s wrong doing are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of:

a) Refusing to take part in, be concerned in or facilitate tax evasion or foreign tax evasion by another person.

b) Refusing to aid, abet, counsel or procure the commission of a tax evasion offence or a foreign tax evasion offence by another person; or

c) Reporting in good faith their suspicion that an actual or potential tax evasion offence or foreign tax evasion offence has taken place or may take place in the future.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance team immediately.

Training and Communication

Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Such training may form part of a wider financial crime detection and prevention training.

Our zero-tolerance approach to tax evasion and foreign tax evasion must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that.

Breaches of This Policy

Any employee who breaches this policy will face disciplinary action which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Potential Risk Scenarios: “Red Flags”

The following is a list of possible red flags that may arise while you work for us and which may raise concerns related to tax evasion or foreign tax evasion. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these red flags while working for us, you must report them promptly to your manager:

a) You become aware in the course of your work that a third party has made or intends to make a false statement relating to tax, has failed to disclose income or gains to, or has delivered or intends to deliver a false document relating to tax, or has set up or intends to set up a structure to try to hide income, gains or assets from a tax authority.

b) You become aware in the course of your work that a third party has deliberately failed to register for VAT (or the equivalent tax in any relevant other jurisdiction) or failed to account for VAT.

c) A third-party requests payment in cash and/or refuses to sign a formal commission or fee agreement or to provide an invoice or receipt for a payment made.

d) You become aware in the course of your work that a third party working for us as an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions.

e) A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business.

f) A third party to whom we have provided services requests that their invoice is addressed to a different entity, where we did not provide a service to such entity directly.

g) A third party to whom we have provided services asks us to change the description of services rendered on an invoice in a way that seems designed to obscure the nature of the services provided.

h) You receive an invoice from a third party that appears to be non-standard or customised.

i) A third party insists on the use of side letters or refuses to put terms agreed in writing or asks for contracts or other documentation to be backdated

j) You notice that we have been invoiced for a commission of fee payment that appears too large or too small, given the service stated to have been provided.

k) A third-party request or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us.

This document will be updated and reviewed periodically by the Board.

Anti-Bribery & Anti-Corruption Policy
This anti-bribery policy exists to set out the responsibilities of ELTRAK SA and its subsidiaries, joint ventures, associates and business partnerships (the Group) and those who work for the Group in regards to observing and upholding our zero-tolerance position on bribery and corruption.

It also exists to act as a source of information and guidance for those working for the Group. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

Policy Statement

The Group is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. The Group has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

The Group will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of Greece, in regard to our conduct both at home and abroad.

The Group recognises that bribery and corruption are punishable by imprisonment and fine. If the Group is discovered to have taken part in corrupt activities, we may be subjected to a fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

Who Is Covered by The Policy?

This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the Greece ). The policy also applies to Officers,, Board, and/or Company’s Committees members at any level.

In the context of this policy, third-party refers to any individual or organisation the Group meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and politic parties.

Any arrangements the Group makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

Definition Of Bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe (active bribery). If an individual is on the receiving end of a bribe and they accept it (passive bribery), they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the Group’s compliance team.

What Is And What Is NOT Acceptable

This section of the policy refers to 4 areas:

• Gifts and hospitality.

• Facilitation payments.

• Political contributions.

• Charitable contributions.

Gifts And Hospitality

The Group accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

b. It is not made with the suggestion that a return favour is expected.

c. It is in compliance with local law.

d. It is given in the name of the company, not in an individual’s name.

e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).

g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.

h. It is given/received openly, not secretly.

i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

j. It is not above a certain excessive value, as pre-determined by the Group’s compliance officer (usually in excess of100 €).

k. The gift is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance officer.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance team which will assess the circumstances.

The Group recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

As good practice, gifts given and received should always be disclosed to the compliance officer. Gifts from suppliers should always be disclosed.

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Group compliance team should be sought.

Facilitation Payments And Kickbacks

The Group does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

The Group does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

The Group recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

a. Keep any amount to the minimum.

b. Ask for a receipt, detailing the amount and reason for the payment.

c. Create a record concerning the payment.

d. Report this incident to your line manager.

Political Contributions

The Group will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

Charitable Contributions

The Group accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

We will 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 Group compliance team .

Employee Responsibilities

As an employee of the Group, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance team.

If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. The Group has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

What happens if I need to raise a concern?

This section of the policy covers 3 areas:

a. How to raise a concern.

b. What to do if you are a victim of bribery or corruption.

c. Protection.

How To Raise A Concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to the Group, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager and the Group compliance team,

The Group will familiarise all employees with its whistleblowing procedure so employees can vocalise their concerns swiftly and confidentially.

What To Do If You Are A Victim Of Bribery Or Corruption

You must tell your compliance team as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.


If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, the Group understands that you may feel worried about potential repercussions. The Group will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

The Group will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the Group compliance teamimmediately and or the wider Group compliance officer

Training and Communication

The Group 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.

The Group’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

The Group will provide relevant anti-bribery and corruption training to employees where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.

Record Keeping

The Group will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.

Monitoring and Reviewing

The Group‘s compliance team is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to: complianceteam@eltrak.gr

This policy does not form part of an employee’s contract of employment and the Group may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

This document will be updated and reviewed periodically by the Board to ensure that it remains up to date, compliant and relevant to the needs of the organisation and its clients.

Disclosure (Whistleblowing) Policy

The law permits workers to disclose certain kinds of wrongdoing and complaints to their employer or, in certain circumstances, to prescribed authorities, without being subjected to any detriment for doing so. This policy sets out our policy on disclosing malpractice (sometimes known as “whistleblowing”).

This Policy has been established to ensure that all cases of suspected wrongdoing are reported and managed in a timely and appropriate manner.

Suggested reporting lines are contained within this policy, however should you feel uncomfortable with or unsure of how the reporting lines apply to your situation please contact the compliance team which will ensure that all matters are dealt with in a timely manner, with sensitivity and by the appropriate person.

In all cases involving suspected fraud you should contact the compliance team immediately.

Policy statement

Whoever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity. It is the responsibility of each and every one of us to ensure that we fulfil this commitment in our day to day working lives. However, from time to time there may be situations where the right course of action is unclear, or there may be situations where you suspect or know that something is improper, unethical or inappropriate. We have both a legal and moral duty to take appropriate measures to identify such situations and attempt to remedy them.

It is sometimes difficult to know whether to speak up about something that concerns us. Often people are reluctant to get involved but this could result in serious consequences for the Company and its employees. That is why we have put in place this Whistle Blowing Policy – so that you can talk to someone confidentially so that we can help. Policy aims

The aim of this policy is to:

• ensure all employees feel supported in speaking up in confidence to report matters they suspect may involve anything improper, unethical or inappropriate;

• encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation;

• provide clear procedures for the reporting of such matters;

• manage all disclosures in a timely, consistent and professional manner; and

• provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.

Approval and adoption

This policy is a statement that improper, unethical or inappropriate behaviour within the organisation is unacceptable and this statement is endorsed and supported at the highest level.

When should I speak up?

This policy is designed to deal with concerns raised in relation to specific issues which are in the public interest and detailed below. Whistle blowing means a disclosure of information made by an employee or contractor, an external person or body where they reasonably believe that one or more of the following matters is happening now, took place in the past or is likely to happen in the future. This is a non – exhaustive list of examples:

• a criminal offence;

• fraud;

• a failure to comply with a legal obligation (e.g. breach of a contractual or other law obligation, statutory duty or requirement or administrative requirement, including suspected fraud or malpractice);

• a miscarriage of justice;

• a danger to the health and safety of any individual;

• violence and harassment

• damage to the environment; and

• a deliberate concealment of information that would indicate any of the above.

Reporting in good faith

If you make an allegation in good faith, but it is not confirmed by investigation, no action will be taken against you. If, however, you make allegations that are malicious or simply to cause anger or distress, disciplinary action may be taken against you. Who should I contact?

We recognise that, due to the potential sensitivity of the situation, you may not always feel comfortable about discussing your concerns internally. As soon as you become aware of any suspected wrongdoing, you should notify the matter to one of the people below in the particular order:

• your line manager;

• your HR contact;

• your divisional director;

• The compliance team

It is preferable if you address your concern to the above persons and bodies in the specific order they indicated above and to address the next one only if the previous one does not respond. But even if this order is not followed, your concern will be investigated..

Concerns raised under this policy will relate to our employees but may also relate to the actions of a third party, such as a supplier, agent, distributor, or joint venture partner.

It is important that you do not publish your concerns outside of our organisation without, at the very least, having allowed us the opportunity to address them internally.

We understand that disclosures made under this policy may involve highly confidential and sensitive matters and that you may prefer to make an anonymous disclosure.

When this is the case we will endeavour to investigate your concerns fully, although a full investigation may be impeded if we cannot obtain further information from you. In order to make an anonymous disclosure send a letter to the compliance team ……

What happens following speaking up?

The person you contact will acknowledge receipt of your concern and reply to you to discuss the next steps with you.

The person managing the meeting may report the incident to other internal departments. Please be assured that these matters will always be kept confidential and where at all possible, the details of the person or persons reporting the incident will be removed.


We will decide how to respond in a responsible and appropriate manner under this policy. An investigation will be conducted as speedily and sensitively as possible in accordance with all relevant laws and regulations. If appropriate, you will be regularly informed on the progress of these investigations and any action to be taken. The purpose of this investigation is:

• to establish if a wrongdoing has occurred, and if so to what extent; and

• to minimise the risk of further wrongdoing, to prevent any further loss of assets, damage to reputation and to protect all sources of evidence.

We will endeavour to handle investigations as fully, promptly and fairly as possible. As far as reasonably practicable, the confidentiality of the person reporting the suspected wrongdoing will be maintained.

It is not possible to set a specific timeframe for completion of investigations in advance, as the diverse nature of potential disclosures makes this unworkable. Most investigations will be managed internally but we may appoint an external investigator or investigating team if we think it appropriate. The process for the management of investigations is outlined in Appendix A.

Any person found to be involved in any wrongdoing will be subject to investigation using the local disciplinary procedure (in the case of employees) or may have their contract terminated (in the case of freelancers, casual or temporary agency staff and contractors). Where it is believed that criminal activity has taken place, the matter may be reported to the police and appropriate legal action taken.

If you are not satisfied with the investigation or its conclusion, you should write directly to the CEO of ELTRAK .

Protection The Company undertakes that no one who reports any concern under this policy in good faith will be subjected to any detriment for coming forward, regardless of whether or not the concern is ultimately substantiated. In the event that an employee believes that they are being victimised or subjected to a detriment by any person within the company as a result of reporting a concern or assisting the company in any investigation under this policy they must inform the HR department or the CEO immediately and appropriate action will be taken to protect them from any reprisal.

Malicious reports

We encourage all disclosures made in good faith. However, deliberately false or malicious allegations are unacceptable, and anyone found to have made such allegations will face disciplinary action and possible dismissal. Similarly, where an individual makes an unjustified external disclosure (other than to a prescribed regulator) without first exhausting the internal procedure set out in this policy, disciplinary action may result.

Cooperation with competent authorities

The Company provides assistance and access to any competent public, administrative or judicial authority when investigating such incidents or behavior, if requested to do so In case that criminal activity has taken place, the matter may be reported to the police and/or judicial or other competent authorities and appropriate legal action taken.

Reporting allegations of fraud

Fraud is perpetrated by an individual enriching itself or a third party by knowingly representing untrue facts as true or by illegally concealing or suppressing true facts to persuade another party to act or omit to act, thus causing pecuniary damage. . In businesses the term fraud (not as an exact legal term but as a financial offense) also includes the misappropriation of money or property.

All actual or suspected incidents of fraud should be reported without delay to the relevant line manager who must then notify the HR Director and the compliance team The latters shall have responsibility to report the fraud without delay to the Finance Director and to the CEO. The Finance Director may also notify the local police and our Insurance Brokers.

A confidential report will be prepared covering:

• quantification of losses (or best estimate);

• strategy for recovery of losses;

• a summary of the resources taken to complete the work;

• actions taken to prevent and detect similar incidents; and

• recommendations on system design to reduce the risk of reoccurrence.

The CEO / Finance Director will then decide the appropriate course of action and whether further investigation is necessary. The purpose of pursuing further investigative work will be done to prevent further loss.

The CEO / Finance Director will distribute any investigation reports to the Board for its consideration of the nature of the incident, how the fraud was perpetrated, the measures taken to prevent a recurrence, and any actions required to strengthen systems and responses to fraud.

The CEO / Finance Director will need to submit a follow-up report to ensure that recommendations have been actioned.

Data protection and privacy

All information shall be treated confidentially as far as reasonably practicable. There may be circumstances where, because of the nature of the investigation or disclosure, it will be necessary to disclose your identity. In such circumstances every effort will be made to inform you before such disclosure is made.

If it is necessary for you to be involved in an investigation (for example by providing evidence), the fact that you made the original disclosure will, so far as reasonably practicable, be kept confidential and all reasonable steps will be taken to protect you from any victimisation or detriment as a result of having made a disclosure.

Further information

If you have any questions about the content or application of this policy, you should contact the compliance team

This document will be updated and reviewed periodically by the Board.

Management of Investigations


Whistleblower raises concern by speaking to line manager and or HR contact and or divisional director and or he compliance team The receiver of the complaint escalates this concern to compliance team.

Whistleblower raises concern by emailing: complianceteam@eltrak.gr

Initial Assessment

Compliance Team identifies the issues. Does this report relate to a breach of Company values, of the law, and /or best practice. Compliance Team considers what information and resources - internal and external – is necessary to properly review the report. Where appropriate the whistleblower will be informed of the review, such reviews can be lengthy and if the whistleblower has further information to share they can do so by email or phone. Compliance team should inform the CEO of the Company that a whistleblowing report has been received and a review will take place.


Compliance team should conduct or direct a formal review of the underlying issues of concern. Where the issue relates to a potential breach of law or legal obligations, the compliance officer should seek advice from internal / external The review should be completed by an assessment of the documentation, followed by discussions with key individuals. A document summarising the review will be produced and provided to the CEO .


On the basis of the issues identified in the review and with appropriate input from colleagues and external advisors, the compliance officer should prepare a document to summarise appropriate steps for resolution. Resolution steps could be short term corrective action (eg disciplinary action) as well as long term structural reforms (eg procedure changes). Where appropriate the compliance team should inform the whistleblower that the review has concluded and how the Company has responded to the issues.

Anti-Violence & Harassment Policy
ELTRAK S.A. (hereinafter the "Company") is committed to maintaining a workplace without discrimination, intimidation and illegal harassment.

This Policy describes the Company's policy prohibiting violence intimidation and harassment.

Basic Principles

The Company shall not accept or tolerate any form of harassment, intimidation , psychological abuse in work aggressive or unjustified behavior, insulting, annoying and generally any unwelcome conduct against any Employee or customer, by a superior, colleague and/or third party, nor any form of discrimination or harassment based on race, colour, religious or other beliefs, gender, age, national or ethnic origin, genealogical, social and professional origins or family or social status, sexual orientation, gender identity or characteristics, physical or mental disability or chronic disease or medical conditions in general, physical appearance, or other element protected by applicable law. Further, biased way of thinking and discriminatory behaviors, the disclosure in the media of written and oral comments, including any jokes, that could be interpreted as sexist, racist, intimidating, offensive or slanderous, are not allowed nor accepted in the workplace Any Employee who becomes recipient or witness of such incidents must immediately inform Company which provides assurances of handling the matter with discretion, confidentiality and efficiency.

What is defined as violence and harassment?

(a) 'violence and harassment' means the forms of conduct, acts, practices or threats thereof , whether a single occurrence or repeated, which aim , lead or are likely to lead to physical, psychological, sexual or economic harm, whether occurring individually or repeatedly;

(b) 'harassment' means forms of conduct which have as their object or effect the violation of the dignity of the person and the creation of an intimidating, hostile, degrading, humiliating or offensive environment, whether or not they constitute a form of discrimination, and which include harassment on grounds of sex or other grounds of discrimination;

c) "harassment on the grounds of sex" means the forms of behavior related to the sex of a person, which have as their purpose or effect the violation of the dignity of that person and the creation of an intimidating, hostile, degrading, humiliating or aggressive environment according to article 2 of Law 3896/2010 and para. 2 of article 2 of Law 4443/2016 (as these provisions will be amended or replaced). These forms of behavior include the sexual harassment of Law 3896/2010 (as these provisions will be amended or replaced),as well as forms of behavior related to sexual orientation, expression, identity or gender characteristics of the person.

More specifically:

Intimidation and Harassment are persistent and unwelcome behavior or actions based on characteristics and attributes described to a person, such as:

• Aggressive or threatening behavior, verbal threats or abuse

• Physical attack, strong innuendoes, offensive expressions, obscene gestures

• Spreading malicious rumors about an individual or group, socially excluding or isolating someone

• Destruction, concealment or theft of personal or work equipment

• Abuse of power by publicly ridiculing a subordinate

• Abuse of power by arbitrarily excluding applications for leave, education or promotion

• when a conduct generally has a purpose or effect that is not reasonably intrusive to a person's work performance or creates an intimidating, hostile or offensive work environment

Sexual harassment is a type of harassment that includes unwelcome sexual suggestions, unwelcome sexual intercourse, unwelcome oral or physical conduct of a sexual nature, unwelcome invitations to sexual compliments, and other unwanted physical, oral or visual conduct of a sexual nature and/or conduct directed at someone because of the gender of this person.

An unwelcome physical, oral or visual behavior of a sexual nature may include any of the following types of conduct:

• explicit sexual propositions,

• sexual innuendoes

• comments, adjectives, or defamatory expressions with sexual insinuations;

• "teasing" or "jokes" of sexual content

• sexual content jokes

• obscene gestures, or obscene expressions

• images or drawings with obscene or sexual insinuations

• viewing sexually offensive graphic materials that are not necessary for the job

• physical contact, such as "light bumps", pinching, or touches

Harassment on any basis occurs every time the acceptance of the harassing behavior is an explicit or implicit term or condition for employment including hiring, loss of employment, demotion or change of responsibilities or benefits;

Unlawful harassment is also the behavior includes any kind of behavior that creates a work environment characterized by offensive, obscene or demeaning comments, based on any of the protected characteristics listed in the basic principles above. This type of harassment includes, but is not limited to:

• racist or demeaning comments based on ethnicity

• downloading, posting, displaying, publishing, photographing, printing, distributing pornographic, obscene, offensive or inappropriate materials or materials of a sexual, ethnic, religious or racist nature

• use of offensive humor, including racist, religious, sexist or ethnically-based jokes

• demeaning comments concerning the sex, race, ethnicity, ethnicity, national origin, age, disability, religion, sexual orientation, gender identity or expression or any other legally protected characteristic of another person

• any communication or act that is harassing or discriminatory

What is not harassment & violence

• Direct employee supervision, including setting performance expectations

• Taking steps to correct performance, such as putting an employee on a performance improvement plan

• Task assignment and guidance on how and when something should be done

• Request for updates or task progress reports

• Approval or refusal for leave

• Request for documentation of absence for health reasons based on the applicable provisions

• Moral or financial reward of excellent employee performance

• Constructive feedback on the performance of the work

The Company is committed to providing assistance, as far as possible and feasible, to any employee who receives such behavior that needs it.

This policy applies in every case, that the forms of intimidation, violence and harassment occur in particular: • in any area of the Company, including public and private areas and places where employees provide work, receive remuneration, take breaks especially, for rest or for food, in personal hygiene and care areas, changing rooms or accommodation provided by the company to its staff and visitors,

• in all kinds of transportation, travel, education, as well as events and social activities related to work or related to the actions of the Company and

• during work-related communications, including those carried out through information and communication technologies.

In addition to the above the COMPANY intends to provide anyone that belongs to its personnel with its assistance and support in cases he/she is the victim of an incident of domestic violence.


The COMPANY a) receives, investigates and manages any complaint or relevant report showing zero tolerance to violence and harassment, with confidentiality and in a manner that respects human dignity and does not interfere with the receipt, investigation and handling of complaints or reports thereof, b) provides assistance and access to any competent public, administrative or judicial authority when investigating such incidents or behavior, if requested to do so, c) provides employees with information on the potential risks of violence and harassment in its area and on the relevant prevention and protection measures, including their obligations and rights in such incidents, including: i. right of judicial protection, ii. right to appeal, file a complaint and apply for a labor dispute to the Labor Inspectorate within the framework of its statutory powers, iii. right to report to the Ombudsman, also within the framework of its legal powers, and (iv) right to complain to the competent body of the company in accordance with the disclosure (whistleblowing) policy. In any case, where a report or complaint of such incident arises within the company, the affected person reserves his/her right to appeal to any competent authority, d) post and make accessible information on the procedures in place to report and deal with such forms of conduct; as well as the contact details for the competent administrative and judicial authorities, in accordance with the provisions in force, e) ensures an accessible, safe and friendly working environment where the relationships between its employees, directors and members are distinguished by mutual respect, kindness, honesty, understanding, trust, cooperation and support, f) shall take all appropriate measures, within its capabilities, and make all reasonable adjustments to working conditions so as to protect employment and support workers - victims of domestic violence.

More specifically:

1. Complaints about behaviors that constitute a violation of this Policy will be accepted in writing or orally and will be taken seriously; anonymous complaints will be also investigated through the procedure of whistleblowing.

2. Anyone who has noticed sexual or other unlawful harassment should report it immediately.

3. Any employee who wants to report an incident of harassment should immediately report the matter to his or her immediate supervisor, or to the director of HR, or to the Company’s compliance team. Although employees are advised to first seek help from their immediate supervisor, they can, at any time, report their concerns to any reporting channel.

4. Any supervisor or director who finds possible sexual or other unlawful harassment should immediately inform the above persons.

5. Inquiries All complaints will be investigated quickly and in detail by the HR manager and / or through the procedure of whistleblowing.

6. If the case is related to the behavior/actions of any of the above persons, then the communication is made directly with any person from the compliance team that is not related to the case and / or through the procedure of whistleblowing. In case the investigation concerns a person participating in the investigation, this will be replaced by another by a decision of the Board of Directors.

7. All employees have a duty of complete confidentiality in case they submit evidence as part of a complaint investigation.

8. Commenting on confidential information and/or spreading rumors shall not be accepted.

9. All employees are protected from victimization, adverse treatment and harmful change of circumstances because they contributed in any way (e.g. complaint, testimony) to the investigation of a complaint of harassment or sexual harassment.

10. The respect of the principles of trust, confidentiality and the protection of personal data is essential. The safest possible procedure for collecting and exchanging information between the parties involved shall be followed. Data protection and confidentiality covers all the company's procedures and duties and continues after their completion. The current legislation on the protection of privacy and personal data is strictly adhered to.

11. Anyone who makes a complaint has the Company’s assurance of:

a. protection against retaliation actions in case of reporting sexual or other unlawful harassment.

b. the Company's commitment to investigate the allegations and take appropriate action.

c. the Company's intention to maintain absolute confidentiality regarding allegations, to the extent practicable.

d. the Company's intention to inform the person who submitted the complaint of the results of the investigation and any action taken;

e. If necessary, medical and psychological evaluation and support of a person should be provided immediately in the most discreet manner possible.

f. the provision of special leave or flexible work arrangements in order to support an employee-victim of violence, in maintaining his/her job and in his/her smooth reintegration after similar incidents.

g. The above shall apply, mutatis mutandis and to the extent possible, also in cases where an employee is a victim of domestic violence.

12. The case must be assessed by the competent authorities in as objective and direct a manner as possible.

13. Decisions. After examining the information collected during the investigation and reaching specific conclusions, the conclusion will be communicated to the Internal Audit, the Audit Committee and the CEO , which will determine what appropriate actions the Company shall take and will notify the decision to the complainant and the alleged infringer as appropriate.

14. If the conclusion is that a misconduct has taken place, the company will take appropriate disciplinary action including dismissal. In the event of serious misconduct, a report will be submitted to the competent authorities. Where appropriate, judicial proceedings and/or any other legal proceedings may be initiated.

15. Recording: A written record of complaints / complaints and the findings to which they result is kept, including the actions that have been taken to handle each case.

16. False, untrue and inaccurate complaints will, subject to the conditions of the law, incur criminal and civil responsibilities of the complainant.