ISSUE DATE
JULY 2024

SCOPE:

The establishment of a Policy outlining the roles, the responsibilities and the key principles the Company applies regarding issues of corruption and bribery.

MAIN POINTS:

1. Scope
2. Objectives
3. Actions of the BoD and CEO
4. Actions of the Directors and Managers
5. Actions of the employees
6. Actions of the Anti-Bribery Officer

RECIPIENTS:

This procedure refers to all DEMO employees, irrespective of their ranking, DEMO suppliers, subcontractors, and partners of the company.

IMPLEMENTATION IN PROCEDURES:

K009 Constant Improvement Procedures
K011 Anti-Corruption and Anti-Bribery System Manual
K010 Anti-Bribery Procedures
A003 Code of Ethics and Professional Conduct

ATTACHMENTS: Ν/Α

 

1. Scope

The Management and executives of DEMO S.A., hereinafter the “Company” or “DEMO,” are committed to the fundamental principles of business ethics and conduct that govern the Company, as defined and analyzed by DEMO’s “Code of Ethics and Professional Conduct,” hereinafter the “Code of Ethics.”

Creating a strong anti-corruption and anti-bribery culture of compliance is a core value of the Company, adding value to the relationships with the customers and the partners, as well as with the public authorities.

2. Objectives

To strengthen the anti-corruption and anti-bribery fight, the Company sets the following objectives:

• All forms of corruption and bribery are explicitly prohibited not only within the Company, but also in the interactions with customers, suppliers, partners, subcontractors and public authorities.
• Compliance with the applicable legal and regulatory anti-corruption and anti-bribery framework.
• Compliance with the guidelines and directives of the National Organization for Medicines (EOF) regarding sponsorships, donations and participation of healthcare professionals in conferences.
• Compliance with the Codes and guidelines of the Hellenic Association of Pharmaceutical Companies (SFEE).
• Constant training and awareness of its employees on anti-corruption and anti-bribery issues to create a compliance culture.
• Encouragement of its employees to report incidents of corruption and bribery in good faith or with reasonable confidence, without fear of retaliation.
• Provision of independent communication channels for all stakeholders to properly report incidents of corruption and bribery.
• Protection of employees who make such reports and those involved in the investigation of the incident from retaliation.
• Ensuring the independence of the Regulatory Compliance Unit and the Anti-Bribery Officer.
• Establishment of a specific framework of indicators for constant monitoring and improvement of the Anti-Bribery and Anti-Corruption Management System.
• Commitment to the continuous improvement of the effectiveness of the Anti-Bribery and Anti-Corruption Management System.
• Following the appropriate legal provisions in case of deviation from the principles of this Policy.

This Policy is binding on all employees of the Company with no exception, irrespective of their functional position and hierarchical rank, including members of the Board of Directors and any third party to whom the BoD has delegated its responsibilities, members of the BoD’ s committees, as well as the independent Committees of the Company, the management executives of the Company
(Directors and Managers, etc.), as well as suppliers, consultants, all types of business partners, and any third party acting on behalf of the Company.

Any employee or business partner can report such issues without fear of dismissal, adverse changes, or any kind of retaliation. Furthermore, the Company commits that staff will not suffer from retaliation, discrimination, or disciplinary action (such as threats, isolation, downgrading, block of promotion, transfer, dismissal, intimidation, victimization, or other forms of harassment) when the employee:

a) refuses to participate or rejects an activity where they have reasonably determined that the risk of bribery is more than low, and the Company has not taken the required mitigating measures, and

b) expresses concerns or makes a report in good faith, or based on reasonable suspicion, regarding attempted, actual or suspected bribery or violation of this Policy or the Anti-Bribery and Anti-Corruption Management System.

Non-compliance with the anti-bribery and anti-corruption regulatory framework poses a high risk, and DEMO has the right to take all necessary disciplinary measures to prevent and restrain such incidents. Committing a bribery entails not only civil but also criminal liabilities under the applicable laws, a s well as termination of the employment relationship with the Company.

In any case, the person responsible for providing clarifications or advice on issues related to the Anti-Corruption & Anti-Bribery Policy is the Anti-Bribery Officer, who is the Director of Legal Affairs, Compliance & GDPR.

 

3. Actions of the BoD and CEO

• To ensure that anti-corruption and anti-bribery issues are incorporated into the Company’s strategy and objectives.
• To implement the anti-corruption and anti-bribery values and culture as expressed by this Policy and the Code of Ethics.
• To ensure the independence of the Compliance Unit and the Anti-Bribery Officer and their direct access to the BoD.
• To promote and create a culture of compliance on anti-corruption and anti-bribery issues according to the principles described in the Policy and the Code of Ethics.
• To guide the employees by his own example to apply the principles and values mentioned in the Code of Ethics and this Policy.
• To approve the present and related anti-corruption and anti-bribery policies.
• To encourage the employees to report issues related to this Policy and the Code of Ethics.
• To protect the employees who have made reports/complaints from retaliation measures.
• To ensure communication channels for reporting by all stakeholders.
• To ensure that ethical issues are taken into consideration when evaluating personnel.
• Any employee has the right not to sign, submit, or allow others to sign or submit on behalf of the Company any document or statement where the employee knows or has reason to suspect that it is false or misleading.
• Procurement/Provision of Services: The Company may engage Healthcare Professionals to provide consulting and other services related directly to their expertise. Any related collaboration/provision of services must meet the criteria set forth in the Company’s relevant procedure (MD-A-0003).
• Sponsorships or donations can be made only to organizations and not to persons, adhering to the provisions of the law, the provisions of the Hellenic Association of Pharmaceutical Companies (SFEE) Code of Conduct and provided that the criteria set out in the Company’s relevant procedure (MD-A-0002) are met.

4. Actions of the Directors and Managers

• To incorporate anti-corruption and anti-bribery requirements into DEMO’s daily operations.
• To monitor the implementation of corruption and anti-bribery requirements and regulatory framework.
• To participate in the assessment of corruption and bribery risks and to propose preventive measures.
• To participate in and encourage company’ s personnel to participate in training actions organized by the Compliance Unit.
• To promote and create a culture of compliance on anti-corruption and anti-bribery issues according to the principles described in this Policy and the Code of Ethics.
• To guide the employees, by their own example to apply the principles and values mentioned in the Code of Ethics and this Policy.
• To encourage the employees to report issues related to this Policy and the Code of Ethics.
• To conduct sponsorships and donations in compliance with the law, the provisions of the Hellenic Association of Pharmaceutical Companies (SFEE) Code of Conduct, and provided that the criteria set out in the Company’s relevant procedure (MD-A-0002) are met.
• To engage Healthcare Professionals for the provision of consulting and other services directly related to their expertise, provided that the criteria set out in the Company’s relevant procedure (MD-A-0003) are met.
• To ensure that no employee signs, submits, or allows others to sign or submit on behalf of the Company any document or statement where the employee knows or has reason to suspect that it is false or misleading.

5. Actions of the Employees

• To implement this Policy as well as the Code of Ethics.
• To actively participate in awareness training organized by the Compliance Unit and the Anti-Bribery Officer.
• To report incidents they become aware of regarding deviations from the principles and values described in this Policy and the Code of Ethics.

6. Actions of the Anti-Bribery Officer

• To ensure through mechanisms the dissemination of regulatory obligations, values, and principles of the Code of Ethics and the Company’s Anti-Corruption and Anti-Bribery Policy to the relevant executives and provide appropriate advice to them and the Management.
• To monitor the implementation of relevant procedures and be responsible for their updating.
• To ensure the protection of employees making reports from retaliation or other acts against them in collaboration with the Management
• To develop and implement procedures for assessing information related to complaints on corruption and bribery issues, e.g., complaints, information from suppliers, from the staff.
• To participate in the drafting of policies related to the implementation of the Anti-Bribery Management System.
• To provide advice and clarifications to the staff regarding the issues of the Code and the Anti-Corruption and Anti-Bribery Policy.
• To be responsible for organizing training programs and raising staff awareness on anti-corruption and anti-bribery to ensure that all involved staff receive the required information and training.
• To issue reports related to corruption and bribery and the level of implementation of the Management System to the CEO and the BoD.
• To maintain direct communication channels with the CEO and the BoD.
• To participate in the identification, assessment and management of risks related to corruption and bribery.
• To define in collaboration with the Management and monitor performance indicators related to the company’s performance in the implementation of the Management System.
• To evaluate due diligence questionnaires from partners/suppliers.
• To evaluate the suppliers/partners on corruption and bribery issues, on an annual basis, in collaboration with the Directors.
• To evaluate professional gifts received or offered by the company’s staff.

 

This document is the intellectual property of DEMO S.A. and any reproduction, republication, copying, storage, sale, transmission, distribution, publication, modification, whether in whole or in part, or in summary, is strictly prohibited without the explicit prior written consent of the Company.