Anticorruption policy

A1. DETAILED ANTI-CORRUPTION POLICY

Bribery/kickbacks and corruption are major threats to good administration, sustainable development, business ethics and good faith between traders. They undermine efforts to achieve economic and social development.

RELATIONAL SA shows zero tolerance for bribery and corruption. The company acts in all its activities guided by ethics, integrity and confidentiality principles. The company’s management is committed to contribute in all possible ways, on its behalf, to the prevention and combating of bribery and corruption phenomena and it is necessary for everyone to contribute to combat such phenomena.

Practices aimed at creating and/or strengthening relationships and promoting the company’s goals must be carried out transparently and must not create any expectation to the recipient thereof to
reciprocate, either by committing or omitting acts or any other action in return.

RELATIONAL SA prohibits any facilitation payment regardless of its value and does NOT make donations to political parties.

All employees and providers – third parties of the company must oppose bribery and corruption phenomena and inform the management of suspicious incidents regarding such phenomena. All
reports will be reviewed by the company’s management in cooperation with the Legal Advisor.

Reports must be made honestly and in good faith under this policy regarding suspicious incidents, even if those suspicions turn out to be false.

Basic Principles

• RELATIONAL SA applies a zero tolerance policy against corruption and is committed to operate with professionalism, legality and integrity in all its business transactions.
• All human resources of the company as well as third parties acting on its behalf are not allowed to offer, promise or bribe anyone, as well as request, to agree to be bribed.
• RELATIONAL SA has established anti-corruption measures in order to maintain high ethical standards and protect its reputation against any accusation of Corruption and Bribery.
• This Policy concerns all human resources of the company regardless of the role and hierarch as well as the providers and third parties of the company, acting on its behalf.
• Failure to comply with this policy, whether it is intentional or unintentional, may lead to disciplinary proceedings, which may result in dismissal or termination of cooperation due to serious misconduct as well as criminal prosecution of the person involved, based on existing Greek legislation.
• Staff are encouraged to report any issue or suspicion of wrongdoing that comes to their attention immediately to management. No one will be affected for reporting serious concerns about bribery, corruption, improper donations and facilitation payments unless proven to have been made fraudulently.

From the Management