CODE OF ETHICS AND PROFESSIONAL CONDUCT
ISSUE DATE 22.01.2025
Objective:

To describe the company’s policies in relation to the values, ethics, employee conduct and company commitments to maintain a healthy work environment.

Key points:

1. Purpose of the Code of Ethics and Professional Conduct
2. Professional Conduct
3. Conflicts of Interest
4. Interpersonal Relationships with colleagues
5. Social Networks
6. Attire and Appearance in the Workplace
7. Smoking – Use of Alcohol and Substances
8. Health – Safety at the workplace & Environment
9. Asset Protection — Theft and fraud
10. Bribery and Corruption – Gifts
11. Anti-money laundering
12. Accuracy and integrity of financial data
13. File Management and Protection of confidential information
14. Protection of privacy and personal data
15. Speak Up/WhistleBlower policy

Recepients:

ALL EMPLOYEES

1. Purpose of the Code of Ethics 

The Code of Ethics and Professional Conduct of DEMO S.A. (hereinafter referred to as “Code of Ethics”) was designed to reflect, in a single text, the general principles and ethical rules governing the professional conduct of all employees of the company, as well as the commitments of the management towards its employees.

DEMO is committed to carrying out its activities with a sense of high moral responsibility and integrity and in full compliance with the relevant legislation governing its business activities. The company and all its employees are required to comply with the applicable legal framework, regulations and standards, policies and guidelines of the company, as well as the present Code of Ethics and carry out all their activities in accordance with high ethical standards and values.

This Code of Ethics applies to all DEMO employees who are obliged to observe it wherever they operate, both inside and outside the company’s facilities and throughout their work and commute.

The Code of Ethics also applies to and is binding for DEMO partners, subcontractors and consultants, who represent or operate in the name or on behalf of the company, either through outsourcing of services or any other business activity.

Please contact the Human Resources Department if you have questions about any of the topics covered by this policy.

2. Professional conduct 

All employees are, at all times, ambassadors of the company. The conduct, appearance and actions of employees should be fully in line with the company’s standards. Employees should not take actions that could potentially discredit the company or cause serious public relations issues through negative publicity that may adversely affect the company in any way.

The company expects all employees, regardless of hierarchical level or professional status and role, to conduct themselves with dignity, professionalism, and courtesy, inside and outside the company, in any form of communication with colleagues or third parties, whether oral, written, or electronic of any kind. The company encourages and ensures the harmonious cooperation of employees at every level and promotes a positive working climate.

How we choose to behave:

  • We remain polite, patient, and calm under all circumstances.
  • We carefully choose our expressions and we do not offend, nor underestimate others. Harassment and exclusionary conduct are not acceptable. This may, for example, include: threats of violent acts, discriminatory jokes, or inappropriate language. Personal insults, with sexist or racist terminology. Encouraging some of the above behaviours is not allowed.
  • We are discreet. We are all part of a team and we all depend on the team’s members for the best possible result as a company. Our decisions affect other colleagues, partners, customers and we have to consider their consequences of them.
  • We show the necessary respect. We may not agree on all occasions, but a possible disagreement is not an excuse for disrespectful behaviour. We do not allow our frustration to lead us to personal attacks.
  • We avoid repeated harassment. If someone asks us to stop something, then we stop. When we disagree, we try to understand why. It is only reasonable to hold different opinions. What is important is to resolve disagreements constructively. We are open and receptive to feedback.
  • Our differences may be our strengths. We may find strength in diversity. Different people have different perspectives on issues that may be valuable in solving problems or producing new and innovative ideas.
  • We encourage a collaborative and friendly environment to achieve positive results.

In any case, not only must all employees refrain from any kind of negative behaviour towards third parties, but they must also cultivate a friendly and pleasant working environment.

Employees are responsible for informing the Human Resources Department of any incident of unacceptable behaviour that comes to their attention, whether it concerns themselves or colleagues.

The company undertakes to investigate each incident, inform the parties involved, and take appropriate disciplinary measures, where necessary.

3. Conflicts of interest 

All employees are responsible for avoiding any situations that present actual or potential conflicts of interest between their personal interests and those of the company. Conflicts of interest can take many forms and arise when the personal, professional, social, economic, or political interests of employees conflict with the interests of the company.

Potential conflicts of interest may include cooperation, employment, ownership or other financial relationship with a competitor, supplier, or customer of the company, acceptance of gifts, money or other benefits of high value from a customer, competitor, or supplier without the approval of management, choice of partner or supplier because of agreement or financial benefit, representation, use and exploitation of the company’s name without the management’s permission, or any kind of investment or financing of a competitor, client or supplier, etc. of the company.

A conflict of interest also arises when a full-time employee wishes to work in parallel with a third company that either competes with the company’s current or future activities or is a supplier of goods or services to the company, or in another undertaking that interferes with the employee’s obligation to devote his full time and attention to his work responsibilities.

In any case, employees are responsible for disclosing any conflicts of interest to their Supervisor and Manager, or to the Legal Department – Compliance Section, or the Human Resources Department.

The Supervisors and Managers of the relevant departments are then required to determine the correct management and management of conflicts, including consulting the Legal Department — Compliance Department and Human Resources Department, when conflicts are significant.

4. Interpersonal relationships with colleagues

The company recognises that employees who work together may establish interpersonal relationships. Although the company does not wish to interfere with these personal relationships, it is necessary to ensure that all employees behave in an appropriate and professional manner at work and that there is no real or potential risk to employee impartiality as a result of their relationship.

Therefore, the following principles apply to all employees, regardless of their job position or hierarchy:

  • Any employee involved in a close relationship with a colleague, client, supplier should not allow the relationship to affect labour relations and transactions during the work. This policy applies during work either within the premises of the company or at the premises of suppliers. Any violation of the rule will be considered disciplinary misconduct which may result in penalties and even dismissal.
  • In order to avoid a situation in which an employee exercises their managerial right over another with whom he or she has a close personal relationship, the company reserves the right to choose to transfer one or both employees involved in the relationship to another department. In these cases, the company will discuss with both employees and look to find the most satisfactory solution regarding the transfer of one or both.

In any case, employees are responsible for communicating possible close interpersonal relationships to their Supervisor and Manager.

5. Social networks

This policy includes guiding principles and applies to all DEMO employees, partners, and agents who use Social Networks to refer to products, assets, information, activities, trade, partnerships, economic development, people, shareholders, directors, employees, colleagues, and/or former partners of the company.

This policy does not apply to the personal use of Social Networks, as long as no reference is made to the aforementioned DEMO information and in no case should it be construed as a prohibition of conduct protected by applicable law. Employees are not allowed to access social networks for personal use from corporate computers. Only access for professional purposes is allowed during work. The company understands that employees may wish to use their personal electronic devices to access social networks during their break.

Employees of the company are free to repost anything that is already posted by DEMO on its official website or on an official social network account. If you have any doubt at any time whether or not to post something on Social Networks or if you have any questions about this Policy, please contact DEMO’s Corporate Communications Department.

If we refer to the above DEMO information or our status as employees, collaborators, or representatives of DEMO, we should make it clear that the statements or opinions expressed on the specific Social Network are ours and do not represent those of DEMO. We must not disclose information or data on behalf of DEMO unless we have been specifically authorised to do so. Please observe the terms of confidentiality that you have agreed in your contract or in a separate non-disclosure agreement with DEMO and/or the confidentiality terms contained in this Code.

Rules applicable in relation to the use of Social Networks:

  • The following may not be disclosed on Social Networks:
    • non-public or unpublished information, if this information was obtained during your employment or cooperation with DEMO;
    • confidential information, trade secrets, know-how information or any other information of similar content belonging to or related to DEMO or any other DEMO-affiliated third-party company;
    • information on economic progress, development, corporate transactions, legal matters, internal investigations or disputes, etc. including in particular any communication messages with DEMO’s lawyers or external consultants. Disclosure of such information to third parties may jeopardise the confidentiality and privileged legal status of such information;
    • internal files, presentations, reports, etc. created as part of your work at DEMO;
    • personal information about colleagues, former colleagues, job candidates, independent contractors, or other natural persons related to DEMO without their express prior consent.
  • We do not post photos or videos of colleagues, employees or other DEMO related persons on Social Networks without the consent of all those figured therein. We do not refer to, identify or comment on any such person on any Social Networks without said person’s consent. We do not post on Social Networks material that infringes the protected intellectual or industrial property rights or trademarks of third parties.
  • We do not use discriminatory, harassing, intimidating, or offensive language on Social Networks with reference to colleagues, former colleagues, job candidates, independent contractors, or other individuals associated with DEMO. Statements and announcements must be free from insults about racial, nationalistic, religious, physical, or sexual characteristics, sexual orientation, or any other discrimination. We do not make false, misleading, or unfounded statements.
  • Beyond neutral references, we strongly discourage all personal opinions concerning DEMO products. In particular, we discourage characterisation statements relating to a DEMO product, including comments that ascribe or imply any benefit or otherwise with regard to the products, the efficacy, clinical trials or safety claims thereof.

All employees are required to comply with the above guidelines. Failure to follow instructions may lead to compliance and/or disciplinary action. In particular, serious violations of the policy, for example incidents of verbal violence to colleagues on social networks or use of social networks that damages the company’s reputation, may constitute gross misconduct and lead to disciplinary action, even termination of the employment contract.

6. Attire and appearance in the workplace

This policy was designed to guide workers on issues of attire and appearance in the workplace. The appearance of all employees must be decent in all circumstances. The policy does not exhaust the identification of acceptable and unacceptable standards of employee dress and appearance.

The company recognises the diversity of its employees’ cultures and religions and will take a discreet approach when it affects clothing and appearance. However, priority is given to health and safety. All employees must be well-groomed and clean at work, whether they work in the company’s premises or outside them.

Where applicable, employees have the obligation to wear the uniform they are given and always use Personal Protective Equipment (PPE). Uniforms must be kept clean at the responsibility of workers and not be altered. Failure to use a work uniform – while deemed necessary – constitutes disciplinary misconduct and raises the issue of disciplinary action, while it is forbidden to work without the use of the necessary PPE, as provided for per job position.

Generally, employees are forbidden from wearing the following during their working time, inside or outside the premises:

• Clothing that carries symbols or slogans that may in any way provoke or offend
colleagues, partners, or customers.
• Dirty or worn clothes.
• Provocative clothing of all types, clothes that leave much of the body uncovered
and generally provocative attire.
• Tracksuits and very open footwear.

7. Smoking – Use of alcohol and substances

Smoking, including the use of electronic cigarettes, is strictly prohibited in all indoor areas of the premises.

DEMO implements a zero-tolerance policy in relation to the use of alcohol and illicit drugs. The use of illegal drugs or alcohol in the workplace results in immediate disciplinary action that may even lead to termination of the employment contract without notice.

The following rules apply:

  • If an employee is found to be consuming alcohol or is considered to be under the influence of alcohol in the workplace or during working hours, this can be considered gross misconduct under the company’s disciplinary procedure.
  • The use of illegal drugs or possession of illegal drugs by any employee in the workplace or during working hours may be treated as gross misconduct under the company’s disciplinary procedure.
  • Possession of medication for any reason other than legitimate medical reasons is prohibited and may be treated as gross misconduct under the company’s disciplinary procedure.
  • The company may ask an employee to perform a voluntary medical examination, including alcohol or drug tests, if they believe or suspect that there is a drug and/or alcohol problem. Said employee may be suspended from work, until the problem is resolved. The company will decide whether to treat this as a disciplinary matter.
  • The company will inform the police if it believes there has been drug abuse by an employee, for which criminal checks are appropriate, either at the workplace or when working on behalf of the company off the premises.

If a doctor legally prescribes medicines that may affect an employee’s ability to perform his job, the employee should inform his/her Supervisor. If an employee suffers from alcohol or drug addiction, he/she must declare the dependency to his/her Supervisor and the company will subsequently provide the necessary assistance. 

8. Health – Safety at the workplace & Environment

The company ensures that its activities are carried out in full compliance with applicable laws and regulations, as well as corporate standards and best practices in health and safety. The protection of health and safety in all areas of the company’s activity is considered of paramount importance. To this end, all necessary, reasonable, and practical measures shall be taken to ensure a safe and healthy working environment to minimise risks.

Employees are personally responsible for ensuring their safety and health at their workplace, to the fullest extent provided for in their work duties, fully complying with the necessary measures and, where appropriate, must make use of Personal Protective Equipment (PPE) as applicable. They must ensure the safety of their colleagues and visitors in their workplaces.

All employees are asked to report their concerns to the Department of Health, Safety & Environment and identify areas of their work, such as precarious working conditions and behaviours, which need to be improved on these issues, thus continuously contributing to efforts to design and implement a better and safer working environment.

9. Asset Protection – Theft and fraud

Trust is a necessary component of business conduct. All employees have a duty and responsibility in relation to the management of the company’s assets. The company provides its employees with the appropriate equipment/facilities to support their work activities. Employees have a responsibility to ensure that all company assets are properly used, maintained, and kept safe. Therefore, employees should take appropriate measures to avoid loss, damage, misuse, and theft of corporate property.

DEMO implements a zero-tolerance policy with respect to theft and fraud and employees play an important role in relation to asset management for the Company.

Employees must protect all assets of the company, tangible and intangible, as well as all resources, pay due attention to their use, which must be solely for purposes related to the work, and take every possible care to avoid waste, damage, destruction, fraud, or theft thereof.

Any employee suspected of theft, fraud, or other illegal activities against the company will be investigated immediately and, if necessary, disciplinary action may be taken up to the termination of the employment contract.

10. Bribery and corruption – Gifts – Hospitality

The company has adopted and implements an anti-bribery and anti-corruption procedure (MS-A-0004) as well as an Anti-Corruption and Anti-Bribery Policy (K-008), the purpose of which is to ensure that no DEMO staff, or third parties acting on its behalf, provide or promise payments, gifts or anything of value directly or indirectly to any individual, so as to influence that individual to conduct or maintain business transactions with the company or to secure an inappropriate business advantage for it. This principle concerns both active and passive bribery.

According to the applicable procedure and policy, all types of bribery to any natural person are strictly prohibited. This prohibition applies to both direct and indirect (through third parties) bribery. No employee of the company shall be permitted to provide, promise, or receive from any natural person any unfair payment, valuable gift, or any other item of value. In addition, it is prohibited to pay, promise to pay, or offer any item of value or any other kind of benefit to any public servant or government official or other person or body, public, be they governmental or private. Among other things, company employees are forbidden from accepting hospitality from external cooperating companies and their employees.

This prohibition applies to both direct and indirect promotions, payments, gifts, or commissions, advisory fees, or other payments that may be made in any way as an incentive or reward. For example, payments through consultants, contractors or subcontractors, agents, or sub-agents. No such benefit must be used as a means of bribery or for any other unfair purpose.

In this context, employees are not allowed to accept gifts of value or hospitality offers that could be considered as an attempt to influence their judgment. In any case, employees are not allowed to accept gifts of value, loans, or other favours from anyone who works with our company or who wishes to do business with our company.

Responsible person for providing clarifications or advice regarding matters related to the Anti-Corruption & Anti-Bribery Policy is the Anti-Bribery Officer, appointed by the Director of the Legal Department – Compliance Section.

Employees are encouraged and required to report any relevant concerns they may have to the Anti-Bribery Officer, or alternatively to their Supervisor, the Legal Department – Compliance Section, or the Human Resources Department as soon as possible.

Issues to be reported include:

  • any suspicious or actual attempts to bribe.
  • concerns that other employees may be bribed or concerns that other employees may bribe third parties, such as customers, suppliers, or government officials.

The Company will fully investigate any cases of suspected bribery. Employees suspected of bribery may be suspended while the investigation takes place. The company will invoke its disciplinary proceedings when any employee is suspected of bribery and proven allegations may lead to the finding of serious misconduct and immediate termination of the employment contract.

The ultimate goal is to create a strong culture of compliance and the fight against corruption and bribery, adding value to the Company’s relationships with its clients and partners, as well as the Company’s relationships with public authorities.

11. Anti-money laundering

The company is committed to complying with all laws and regulations relating to financial crimes, preventing these crimes and taking all necessary steps not to be used as a means for money laundering activities, or for any other activity facilitating money laundering or financing terrorist or criminal activities.

All employees are obliged to immediately report any such suspicious activity to the Legal Department — Compliance Department.

12. Accuracy and integrity of financial data

In accordance with the anti-bribery and corruption procedure (MS-A-0004) already in force adopted by the company, all reports of the company’s financial data should be accurate and timely and reflect the actual data. There shall be, for any reason, no false, artificial or misleading entry into the books or records of the company. Any transaction other than that described in the relevant documents proving its validity and conformity and the non-inclusion of any capital or assets in the relevant books and records of the Company is prohibited.

All company employees must, within the framework of their duties, send to the competent departments and auditors accurate and true information about the company’s finances, in order to present accurate and complete financial representation of the company, in accordance with what has been mentioned above.

13. File Management and Protection of confidential information

Correctly and accurately keeping all records is a necessary condition for the proper functioning of the company. The archives keep and safeguard all the information created and used in the context and for the needs of the company’s activity. Employees who, due to the nature of their work, keep records, must ensure their accuracy and completeness.

All employees must, in the exercise of their duties, as well as in any kind of transactions or relationships with third parties, not disclose or make available in any way information of the company which is confidential or secret. Confidential or secret information is information that has not been disclosed or is not available to the general public. Confidential or secret information may be financial or technical data, contracts, personal data of employees, commercial plans and any kind of information related to the development and strategy of the company. Also, confidential or secret information may be information related to copyright, patents, other industrial property rights or company know-how secrets. It may also include business research, new product plans, strategic objectives, any unpublished financial or pricing information, customer and supplier lists, as well as information related to requirements, business options, or customer plans.

It is the obligation of all employees to preserve the confidential and secret information of the company, regardless of the way and reason it came to be known to them, and not to disclose it to persons outside the company, including members of their family and acquaintances, throughout their working relationship with the company, but also in perpetuity after its cessation or termination in any way.

14. Protection of privacy and personal data

The company fully respects the right to privacy and the protection of the personal data of all people with whom it comes into contact. The company seeks to comply with the current regulatory framework regarding the protection of privacy and personal data at its

place of activity. The company’s goal is not only formal compliance, but substantial and lasting compliance with the current regulatory framework. For this purpose, it has established internal Procedures and Policies, which it applies to all data processing procedures it carries out.

It is the obligation of all employees in the performance of their duties to apply the Procedures and Policies set by the company, to comply with the written and oral instructions of their supervisors regarding the processing of personal data, to cooperate with the Data Protection Officer, to report any incident or eventual incident of a data breach and, generally, to comply with all the obligations they undertake regarding the processing of personal data towards the company.

15. Speak Up & Whistleblower policy

All employees and workers of the company have the opportunity to promptly report any confirmed or potential incident of law or regulation violation, any fraud, improper or illegal behavior, as well as any breach of this Code of Ethics by employees or executives of the company or any other person to whom the Code applies, either within the Company via email to: yppa@demo.gr or through the whistleblowing hotline (SpeakUp), which will then be forwarded to the Responsible for Receiving and Monitoring Reports (RRMR), or outside the Company, directly to the competent authority, namely the National Transparency Authority. The Responsible for Receiving and Monitoring Reports (RRMR) is the Director of the Legal Department – Compliance Department.

The main reporting channels of the Company are the email address: yppa@demo.gr and the whistleblowing hotline 8004000005 (SpeakUp) (SpeakUp), through which both anonymous and named reports can be submitted 24 hours a day, 7 days a week.

Employees should be aware of the following:

  • Everyone must be aware of the importance of preventing and eliminating offences at work. Employees should be vigilant of illegal or immoral conduct and report any such conduct they perceive. All employees are required to speak openly when they have questions, worries or concerns. In this way we help minimise risks. Everyone is encouraged to disclose freely any illegal, inappropriate or irregular activity or any activity that deviates from the principles of the Code of Conduct and may be cause for concern, if they become aware of it.
  • Reports can be made either anonymously or with identification. The RRMR conducts a thorough investigation of the relevant reports, ensuring compliance with personal data protection requirements while maintaining the confidentiality of the information, unless otherwise stipulated by applicable law. However, in any case, an identified report of a violation is considered more reliable, as it allows for direct communication with the individual submitting the report to provide clarifications and additional information during the investigation process.
  • Individuals who report irregularities are explicitly protected from any form of retaliation (e.g., dismissal, demotion, harassment). If retaliation occurs, the individuals making the report have the right to appeal to the competent court and seek redress.
  • The RRMR must confirm receipt of the report to the reporter, in the case of an identified report, within seven (7) business days from the date of receipt. Subsequently, it must take the necessary actions to ensure that the relevant authorities of the Company address the report.
  • In any case, the RRMR must provide an update on the progress of the investigation within a reasonable timeframe, which cannot exceed three (3) months from the confirmation of receipt of the report, or if no confirmation has been sent, three (3) months from the end of the seven (7) business days following the submission of the report.
  • If improper conduct is found, as a result of any investigation within the framework of this policy, all applicable procedures of the company, such as any disciplinary measures and, depending on the infringements, the necessary procedures and penalties, will be used. Any cover-up of misconduct is in itself a disciplinary misconduct
  • Maliciously making a false claim is a disciplinary misconduct. The reporting process should not be misused for reckless accusations or personal complaints.
  • Supervisors and Managers shall ensure that no retaliation of any form or action will be taken against any employee who reports, in good faith, any actual or potential misconduct

Cases of violations of the Code of Ethics can also be reported by phone or mail, as well as via email (either identified or anonymous) to the National Transparency Authority, as well as to the following individuals/departments: 

  • The supervisor or manager of the person making the report
  • The Legal & Compliance Department
  • The Human Resources Department

 

 

This is the intellectual property of DEMO S.A., and it is expressly prohibited to reproduce, republish, copy, store, sell, transmit, distribute, publish, modify it in any way, in part or in summary without the express prior written consent of the Company