Whistleblowing – Submission of Reports or Comments

In order to strengthen corporate governance measures and ensure the highest standards of ethics, morals and lawful business conduct, Ethniki Asfalistiki has adopted a reporting procedure in accordance with the provisions of Law 4990/2022 and Joint Ministerial Decision 47312/2023 of the Ministers of the Interior, Labour and Social Security, and Justice (Government Gazette, Series ΙΙ, Νο 6944/11.12.2023).

The Company has appointed a Reporting Manager (RM) responsible for handling and monitoring reports.

Our goal is to always operate in accordance with the principles and values of the Company’s and the Group’s the Code of Ethics, the applicable legislation, and the internal policies and procedures.

We follow practices to ensure that confidentiality and secrecy are kept, so that you feel confident to contact us and report any issues.

What can I report?

Any irregular activity or failure or omission related to breach of internal policies, procedures, rules of conduct, and the applicable legislative and regulatory framework, including violations of Community law falling under the provisions of Law 4990/2022.

Who can submit a report?

Persons who have a work relationship with the Company or its subsidiaries and in particular:

• Employees of the Company or of another company within the Group, regardless of whether their employment is full or partial, permanent or seasonal, or whether they are posted from another entity;

• Collaborators without an employment relationship, self-employed persons, consultants or homeworkers;

• Shareholders and persons sitting on the Board, including non-executive members, as well as volunteers and paid or unpaid interns;

• Persons working under the supervision and instructions of contractors, subcontractors and suppliers;

• Persons who report or disclose information about violations, which has come to their knowledge in the context of a work relationship that has been terminated for any reason, and persons whose work relationship has not yet begun, in cases where information about violations has come to their knowledge during the recruitment process or at another stage of the pre-contracting negotiations.

It is emphasized that this possibility is available to anyone who wishes to submit a report, regardless of whether they are members the Company’s staff or not.

What are the ways to submit an internal report?

The Company has appropriate whistleblowing channels that guarantee the confidentiality and secrecy of such reports, as well as the protection of any person who, acting in good faith, expresses concerns about violation of professional conduct, illegal behaviour, discrimination, or other failure/serious irregularity, from any retaliatory acts.

The internal report may be submitted in Greek or in English, it may be signed or anonymous, made in writing or orally, or through the electronic platform that operates on the Company’s website.

What procedure is followed after the submission of the report?

After the submission of the report, the RM acknowledges receipt to the reporting person within seven (7) working days from the date of receipt.

The RM informs the applicant of the actions undertaken within reasonable time, which shall not exceed three (3) months from the acknowledgment of receipt or, if no acknowledgment of receipt has been sent to the reporting person, three (3) months after seven (7) working days have elapsed since the submission of the report.

The RM facilitates the reporting person in submitting their report by providing them, if requested, with all necessary information about their rights and the established procedure for handling reports.

The RM is not obliged to send an acknowledgment of receipt to the reporting person, if such notification is impossible due to lack of appropriate contact details for the reporting person.

If the report is manifestly unreasonable, vague, incomprehensible or is submitted in bad faith, or does not contain facts that constitute a violation or there are no serious indications of a violation, the RM will archive the report and inform the reporting person accordingly.

Can I also submit an external report?

Law 4990/2022 provides for the possibility of submitting an external report to the National Transparency Authority (NTA). More information can be found on the NTA website.

We would ask you to submit reports responsibly, conscientiously, in good faith and in a professional manner. Fraudulent reports intended to harm the integrity or reputation of another person are prohibited.

We thank you for your participation in the Company’s ongoing effort for and commitment to a) zero tolerance towards behaviours that may be related to infringements/unethical conduct, and b) maintaining high standards of governance and ethics.

Finally, it should be noted that the above channels do not constitute a pathway for the submission of client objections and complaints.

If you have encountered a problem as a client of the Company or you are not satisfied with our products and services and would like to submit a request or a complaint, please follow the following link and we will launch an impartial investigation.