Reporting Policy

DECEMBER 2023

Scope of application

ELVIDA FOODS S.A.

Date of validity

17.12.2023

Version

1.0

Approval

Board of Directors

Categorization

Politics/Policy

Power Level

Binding/Binding

1.  INTRODUCTION :

“ELVIDA FOODS SA”’ has taken the necessary measures to ensure good corporate

governance and compliance with all the regulatory obligations governing its operation. To this end,

the Company has drawn up and adopted the Reporting Policy (hereinafter the “Policy“), which

provides general guidelines and instructions regarding the management of, inter alia, reports of

violations of European Union law.

The Company encourages all those referred to herein to report, confidentially or

anonymously through existing reporting channels, conduct that is illegal or unethical, as soon as it

comes to their attention. Failure to report may in some cases constitute a criminal offence where there

is a legal or contractual obligation to do so. All reports will be taken seriously and investigated with

full objectivity and independence. The Company assures that those who make reports will be

protected from any retaliation and that the personal data of all parties involved are protected by

applying the necessary technical and organisational security measures. The Reporting Policy is

adapted to the principles and provisions of Law 4990/2022 “Protection of persons reporting

violations of EU law – Implementation of Directive (EU) 2019/1937 of the European Parliament and

of the Council of 23 October 2019 (L 305) and other urgent provisions”.

2.  PURPOSE :

The purpose of the Reporting Policy is to:

α) To define the principles and framework for reporting within the Company.

1. b) Encourage the reporting of incidents that have taken place in the Company related to

violations of EU law in the areas of public procurement, financial services, products and markets,

prevention of money laundering, financing of terrorism, product safety and compliance, transport

safety, environmental protection, radiation protection and nuclear safety, food and feed safety, and

the prevention of money laundering; 2 of Article 26 of the EU Treaty, including infringements of

Union competition and State aid rules, as well as infringements relating to the internal market

concerning acts in breach of the rules on corporate taxation or arrangements the purpose of which is

to secure a tax advantage that frustrates the object or purpose of the applicable corporate tax

legislation.

1. c) To provide assurance that reports and investigations of incidents are handled in complete

confidentiality, that the personal data of the parties involved are protected and that those who report

will be protected from retaliation.

1. d) The application of Law 4990/2022 and the international and European best practices

applicable to company reporting in accordance with the OECD and the European Union.

3.  TERMS :

Report: the oral or written provision of information regarding violations of this policy.

α) “Internal report”: the verbal or written provision of information on violations to the

Company’s Receiving and Monitoring Officer (RMO/YPPA).

(b) “External reporting” means the provision of information on violations to the National

Transparency Authority (NTA) orally or in writing or through an electronic platform.

Inadmissible Report (or inadmissible Report): a Report that refers to a violation that does

not fall within the scope of this Agreement, or a Report that is not clear, definite, complete, timely or

is manifestly malicious, frivolous/excessive and repetitive.

Reporting party: a person who reports or discloses information about violations obtained in

the course of his or her work.

Retaliation: Any direct or indirect act or omission that occurs in an employment context as

a result of an internal Petition and that causes or is likely to cause undue harm to the Petitioner.

External partners: Third parties contractually linked to the Company and their personnel,

namely consultants, subcontractors, contractors, suppliers, suppliers, mall retailers, partners of all

kinds, shareholders, etc.

Committee for the Management and Evaluation of Petitions (hereinafter referred to as the

“CMP”/EDDA): The three-member committee charged with the management and investigation of

petitions.

Employee: a person who contracts with the Company under any contract or employment

relationship, as well as a person who is a seasonal employee or a person employed as a trainee by the

Company.

Reporting channels: The channels through which reports are submitted and include the

means used to submit reports and the persons to whom the reporters can be addressed.

Malicious Report: A Report that is made with the Petitioner’s knowledge that it is not true.

Receiving and Monitoring Officer: the Receiving and Monitoring Officer (YPPA) for reports

of violations falling within the scope of this Agreement.

4.  APPLICATION FIELD :

α) Subjective scope of application

The Reporting Policy applies to persons who report information about violations obtained

in the course of their work, i.e. to members of the Board of Directors, Directors and staff of the

Company, regardless of the type of contract or employment relationship that links them to the

Company (employment contract/service contract, trainees, seasonal staff, job candidates, consultants,

self-employed, etc.).

The scope of protection of this Policy also includes third-party contractors of the Company,

suppliers, consultants, consultants, partners of any kind, under project contracts, independent

services, paid assignments, persons employed through third-party contractors of the Company,

persons attending training, including trainees and apprentices (whether paid or unpaid), persons

whose employment relationship has been terminated for any reason, including retirement, and persons

whose employment relationship has not been terminated for any reason, including retirement, and

persons whose employment relationship has been terminated.

A condition of inclusion in the scope of protection of this policy is that the report is made in

good faith, i.e. those making the report have reasonable grounds for believing that the information

they provide is true. In all cases, good faith shall be presumed unless it can be shown that the

Reporting was made in bad faith. In the event of a malicious report, it goes without saying that the

protection described in this policy is not afforded.

(b) Objective scope

Reports of irregular, unethical, illegal or criminal conduct in connection with the Company’s

operations include: 4 / 12

Gonata 40, 121 33 Peristeri, Greece

Tel. +30 210 5785051

Fax +30 210 5785052

Violations of the applicable legal and regulatory framework, violations of the Company’s

Operating Regulations, Code of Conduct, Regulations, Policies and Procedures, criminal acts, acts

that endanger public health, acts that endanger the protection of the environment, acts that endanger

the health and/or safety of employees, shareholders, members of the Board of Directors, executive

and non-executive, executives, members of the Committees, external collaborators, members of the

Board of Directors, members of the Board of Directors and external collaborators.

PRINCIPLES:

The principles underlying the Reporting Policy are the following:

ANONYMITY: A central and integral principle of the policy is the protection of the

anonymity and confidentiality of the personal data of each petitioner.

EXCEPTION: In the case where the petitioner participated in the event and bears part of the

responsibility, he is not relieved of his consequences and responsibilities. However, the report and

his/her contribution to the detection and investigation of the illegal acts will be taken into account in

his/her favour. This will be seen as a genuine attempt at repentance, at least in terms of the company’s

claims against those responsible and the company’s judicial approach.

EQUALITY: All reports are in principle treated equally by the CAA and the NCA, regardless

of the origin or the act complained of.

TRANSPARENCY: The reporting process also aims to enhance the transparency of

corporate action and strengthen the company’s regulatory compliance.

PROTECTION: The bona fide reporter is not subject to retaliation, regardless of the validity

or outcome of his/her report, and is protected from any reactions of the persons complained about.

However, if the reporting party has acted in a malicious manner or with the intention of causing harm

or unlawful interference with the rights of wrongfully accused persons or third parties, then the rights

of the latter are protected.

CONFIDENTIALITY: The Company provides all guarantees to ensure that the reporting

process respects the confidentiality conditions as specified by this Policy, the Company’s Privacy

Policy and the applicable national and European legislation, both with regard to the content of the

report and any information that may lead to the identification of the person disclosing it. Personal

data and any kind of information that may lead, directly or indirectly, to the identification of the

reporting party, shall not be disclosed to anyone other the authorized persons who are competent to

receive, monitor and investigate the reports, i.e. beyond the three members of the Report Management 

and Evaluation Committee, the Y.P.P.A., any qualified external consultants specifically called upon

to investigate the incident, unless the Reporting Party has given express consent or the Report is found

to be malicious. To this end, the Company shall take appropriate technical and organisational

measures, such as pseudonymisation techniques, when submitting, receiving and monitoring the

Report and when communicating with the competent authorities, if deemed necessary. In any case,

during the investigation of an incident, the identity of the Reporting Party shall not be disclosed to

anyone else.

INVESTIGATION CONFIDENTIALITY: The Hellenic Statistical Authority and the NCA

must maintain confidentiality and protect the confidentiality of information that comes to their

attention in the course of the investigation.

5. SUPPORT

Ms Dimitra Giatagana has been appointed as the Receiving and Monitoring Officer (RMO/YPPA).

The Management and Evaluation Committee is composed of 3 members and 3 alternates:

Regular members:

Sofia Politsou

George Karamanolis

iii.

Christina Papachristou

Alternate members:

Yianna Karamitsa

Petros Lykas

iii.

Asimenia Karagianni

In case the report concerns one or more members of the Management and Evaluation

Committee (EDAA), the YPPA limits itself to registering the report in the relevant register of reports

and forwarding it to the National Transparency Authority as an external reporting channel, informing

the reporter.

6.  EXTERNAL CONSULTANTS :

Where necessary and depending on the scope of the investigation, additional professional

support will be obtained from external partners, such as legal advisors, external auditors, fraud 

investigators and specialised experts. At the end of the investigation, the external consultants may

suggest and assist in the establishment or improvement of policies, procedures and controls where

these have been inadequate.

The external consultants should be highly qualified and should not have a relationship with

any natural or legal person which could constitute a conflict of interest. External consultants may

have access to the information, provided that appropriate safeguards, such as a Confidentiality and

Data Protection Agreement, are in place.

The involvement of external consultants/experts is necessary in some cases for the following

reasons:

– They have the required knowledge, skills and experience in specialised subjects.

– They can reach firm conclusions as to the investigation of individual items, ensure the

legality of the process, the completeness of the evidence and the speed, in order to

avoid as much as possible the obstruction of the Company’s business operations due

to the audit.

– They have the necessary independence and neutrality to ensure that the outcome of

their investigation enjoys greater credibility with shareholders, investors, public

bodies, independent authorities or other third parties.

7.  COMPLIANCE WITH THE POLICY – DUTY TO COOPERATE :

All those referred to in the scope of application must comply with this Policy and cooperate

with the RMO/Y.P.P.A., the E.D.A.A. and their authorised partners in the conduct of the internal

investigation, as non-cooperation will make the work of the investigation extremely difficult.

Employees shall be bound as to their obligation to comply and cooperate by explicit contractual terms

contained in the employment contract. And external collaborators are bound by written contracts that

include specifically worded terms that they accept the Company’s policies and procedures, including

this policy, under which they must cooperate. An employee’s direct or indirect refusal to

comply/cooperate with an internal investigation may result in disciplinary action. At the beginning

of the interview, employees and external partners are informed, inter alia, of the consequences of non

compliance and non-cooperation at the investigation stage.

8.  CENTRAL REGISTER OF REFERENCES:

EDAA shall maintain a common electronic and physical archive that includes copies of all

notices related to the collection and retention of data as well as copies of documents, data, information

and all evidence, interview transcripts, the investigation report and decisions of the supervisory

bodies. The file shall meet all technical security requirements and shall be accessible only to

authorised persons involved in the investigation work.

9.  REFERENCE CHANNELS :

The Company has arranged for the establishment of multiple reporting channels for persons

wishing to submit reports. Any of the above mentioned persons who suspect that any of the above

misconduct is being committed shall first address in person or by telephone or email to their

immediate supervisor or manager. If he/she has any concerns (e.g. if he/she fears retaliation or

suspects the involvement of his/her supervisor or manager), he/she may address any of the three

members of the Management and Evaluation Committee or the Management and Evaluation

Committee as a body (EDAA), or directly to the Receiving and Monitoring Officer (YPPA). The

above also applies when the petitioners are not employees of the Company.

10. GUIDELINES FOR REPORTING :

Α) The Report should be made in good faith and without delay, as soon as it becomes

apparent. It is clarified that “without delay” means reports that take place:

(i) within a period of twelve (12) months from the time when matters of a financial nature or financial

impact (e.g. contracts, tendering procedures, negotiations, etc.) become known;

(ii) within a period of six (6) months from the time issues with no economic dimension or economic

impact (e.g. incidents of conduct, discrimination, harassment, etc.) become known;

1. B) The Report should be clear, defined and contain as much information and detail as

possible in order to facilitate its investigation.

1. C) The Report should include the name of the person (or persons) who may have committed

misconduct, the date/time period and place where the incident took place, the type of misconduct and

as detailed a description as possible.

1. D) The Petitioner need not be absolutely certain of the validity of his/her Petition. He should

not take illegal actions that may put himself, the company or a third party at risk in order to seek and

collect more evidence to support his Report.

1. E) The Petitioner should be available, either confidentially or anonymously, to provide

further information upon request. In particular in the case of an anonymous Petition, the Petitioner

may choose to be available through any other specific communication route or specific point of

contact (at the Petitioner’s sole discretion).

11. RESPONSIBILITIES FOR THE RECEIVING AND MONITORING OFFICER

OF REPORTS

YPPA has the following responsibilities:

(a) provide appropriate information on the possibility of reporting within the Company and

communicate the relevant information in a prominent place within the Company,

(b) receive reports of violations falling within the scope of this Agreement,

1. c) acknowledge receipt of the report to the petitioner within seven (7) working days,
2. d) take the necessary steps for the competent body/evaluation committee of the Company to

take up the report,

(e) ensure that the confidentiality of the identity of the reporter and any third party named in

the report is protected by preventing access to it by unauthorised persons,

(f) monitor the reports and maintain communication with the petitioner and, if necessary,

request further information from the petitioner,

(g) provide information to the petitioner on the actions taken within a reasonable period of

time, which shall not exceed three (3) months from the acknowledgement of receipt, or if no

acknowledgement has been sent to the petitioner, three (3) months from the expiry of seven (7)

working days from the submission of the report,

(h) provide clear and easily accessible information on the procedures under which reports

may be submitted to the National Transparency Authority and, where appropriate, to public bodies

or institutions, bodies, offices or agencies of the European Union,

1. i) designs and coordinates training activities on ethics and integrity, participates in the

development of internal policies to enhance the integrity and transparency of the Company.

1. j) seeks specialised and experienced internal or external collaborators depending on the

needs of the research and cooperates with the EDAA.

12. RESPONSIBILITIES OF THE COMMITTEE FOR THE MANAGEMENT

AND EVALUATION OF REPORTS :

The management of the reports submitted through the Reporting Channels is carried out by

EDAA, which has the following responsibilities:

• Review the admissibility of reports that come to its attention from all of the Company’s established

reporting channels.

• Evaluate and prioritise reports.
• Communicate with the Petitioner, when foreseen.
• It shall take all appropriate measures to protect the personal data of the subjects involved in the

reports and shall ensure their erasure in accordance with the time limits laid down.

• It shall keep a Central Register of Reports.
• It cooperates with Y.P.P.A.

13. PROTECTION OF PETITIONERS :

The Company protects those who report in good faith, illegal or unethical conduct. In this

context, any kind of negative behaviour against anyone who has made a Report is prohibited, even if

the Report is proven to be, as a result, incorrect. In particular, the Company is committed that

employees who have made a Report will not suffer retaliation, harassment or marginalisation,

intimidation or threats and unfair treatment as a result of their Report, (e.g. dismissal, unfounded

negative evaluation, denial of leave, exclusion from training courses, denial of expenses, etc.). Also,

unjustified changes in the employment relationship as a result of the Referral are not permitted (e.g.

dismissal, suspension, demotion or deprivation of promotion, reduction in salary, change of

workplace, relocation, diversification of duties, change in working hours, etc.). In the case of a

malicious reference, the above protection does not apply.

The same level of protection applies to third parties connected to the petitioners who could

be retaliated against in a work context, such as colleagues or relatives of the petitioners. Where the 

Petitioner is an external contractor, early termination or cancellation of a contract for goods or

services as a result of the Petition is not permitted.

Any retaliatory action should be reported directly to, investigated and resolved by EDAA. If

the investigation reveals that retaliation has indeed occurred, disciplinary action will be taken against

the perpetrator. The person accused of having committed the retaliation has the burden of proving

that his/her actions are not related to the Report made by the employee (reversal of the burden of

proof).

In the event that an employee decides to make a Report regarding an incident covered by

this policy in which he/she was previously involved, the fact that he/she eventually reported it will be

taken into account in his/her favour in any other subsequent proceedings (e.g. disciplinary

proceedings).

In case the reporting employee expresses the wish to be provided with special protection

from any retaliation (e.g. transfer to another department), the Company will consider the possibility

of satisfying the relevant request within the existing possibilities.

In case the Report is made by name and after investigation it is proven that the Company has

protected vital financial or other interests of the Customer, the person who made the Report will be

rewarded in the most appropriate way possible.

14. RIGHTS OF THOSE MENTIONED OR INCLUDED IN THE REFERENCE :

The Petitioner has the right to be informed both of the receipt of his/her Petition (within 7

working days at the latest) and of the outcome of the investigation (within 3 months at the latest). The

way of being informed is specified in the Reporting Policy. Investigations are carried out in complete

confidentiality and with respect for confidentiality at every stage of the procedure, as far as possible,

in order to avoid stigmatisation and victimisation of individuals. Individuals included in reports have

the right to be called to account. The identity of the Petitioner shall remain confidential. Exceptionally,

if the report is found to be malicious, and if the complainant so requests, he or she may be informed

of the identity of the reporting party in order to exercise his or her legal rights. It is clarified that

Reports which are proven to be patently malicious will be further investigated at the Company’s

discretion both as to the motives and the parties involved in order to restore order by all lawful means

and methods.

15. CORRECTIVE ACTIONS AND DISCIPLINARY SANCTIONS :

Depending on the results of the investigation, EDAA recommends corrective or

disciplinary/legal actions. These actions may include (but are not limited to) (a) additional employee

training, (b) establishing new internal controls, (c) modifications to existing policies and/or

procedures, (d) disciplinary sanctions including permanent removal/dismissal, or (e) and legal action.

16. PERSONAL DATA :

Any processing of personal data under this policy is carried out in accordance with the

national and European legislation applicable to personal data and the Company’s privacy policy. The

data of all parties involved are protected and processed solely and exclusively in relation to the Report

in question and for the sole purpose of verifying the validity or otherwise of the Report and

investigating the specific incident. Sensitive personal data and other data not directly related to the

Report shall not be taken into account and shall be deleted. Only those involved in the management

and investigation of the incident may have access to the data contained in the reports. Personal data

shall be deleted within a reasonable period of time from the completion of the investigation initiated

on the basis of the Report. Personal data will be deleted from the Report Register from material

obtained during the investigation in accordance with the timeframes set out in the Report

Management Policy.

17. INFORMATION AND TRAINING ON REPORTING POLICY :

The Company ensures that all its employees are informed and trained on the content of this

Policy. The information is provided through the sending of informative material, emails, newsletters

or other appropriate means depending on the category of employees. Information about the policy is

also posted in a prominent place on the Company’s website. Training (face-to-face or online) is

provided on a regular basis.

The external partners are contractually bound to provide relevant information to their staff.

This will be done according to the instructions and with the help of material provided by the Company

and by any appropriate means, such as email, sending information material, etc. The information and

awareness-raising activities should be disseminated internally.

19. SUBMISSION OF AN EXTERNAL REPORT:

In addition to the internal report, there is also the possibility of submitting an external report

to the National Transparency Authority (NTA), which acts as an external body. The submission of a

Report to the N.A.D. can be made in writing, orally or via the N.A.D.’s online platform. Details on

how to submit a Report to the N.A.D. can be found at https://aead.gr/ and more specifically at

https://aead.gr/submit-complaint.

20. COOPERATION WITH COMPETENT AUTHORITIES :

To the extent that the report relates to violence and harassment within the meaning of articles

3 and 4 of Law 4808/2021, the Company shall ensure cooperation and provide any relevant

information to the competent authorities, upon request.