The SpeakUp system is a comprehensive telephone system for reporting breaches of applicable national and European law, regulations, policies, and procedures as well as the DEMO Code of Ethics and Professional Conduct. It operates 24 hours a day, 7 days a week and is provided by a third party (Grant Thornton Greece) as a toll free number only available when calling through a landline, providing employees, including contract workers, self-employed, paid employees, third-party service providers, and former employees as well as suppliers and other business partners an anonymous and secure reporting channel.

Any case of behavior that violates applicable national and European legislation and the regulatory framework, company policies and procedures as well as the Code of Ethics and Professional Conduct should be reported. In this regard, both information and reasonable suspicion of actual or potential breaches that are or may be committed are protected.

Indicative incidents of misconduct or breach of law or regulation that may be the subject of a report include: financial, accounting or auditing irregularities, forgery of documents or records, fraud or theft, conflict of interest, bribery or corruption, discrimination, harassment, acts of violence, security or environment risk, violation of human rights, public health and consumer protection, breaches of privacy, personal data protection and network and information systems security, misuse of confidential information, criminal activity, retaliation, etc.

Employees remain DEMO’s first and best line of defense against misdemeanors. We encourage everyone to speak openly and raise issues of misdemeanors they may have identified. By detecting and reporting misdemeanors, employees help maintain the company’s principles, as DEMO can take immediate remedial action, thus preventing future incidents and ensuring a healthy and friendly work environment for all employees.

We undertake that the submission of a report will not lead to any act of retaliation against the employee who has filed it or is likely to have acted or participated in its management. Retaliation against an employee who has filed a report or has assisted in the investigation of a report may constitute a disciplinary offense.

A report can be either anonymous or signed. The company gives every assurance that it will take every reasonable measure to minimize the risk of revealing the identity of the user of the SpeakUp service.

Should you choose to submit a report anonymously, please, make sure that you provide enough details to allow the proper investigation of the reported incident. More specifically, the following information should be included in the report: a brief description of the incident, your relationship with the company, the names of the persons involved or the persons who may be aware of the incident, and finally, the date and time of incident occurrence.

Our company takes all reports of potential misconduct seriously and has appointed a dedicated investigation committee, the members of which are responsible for the thorough investigation of reports so that appropriate action is taken. All investigations will be conducted carefully, in confidence and professionally. If the incident undergoing investigation proves to constitute a breach of law or regulation and needs to be further investigated, any persons involved will be informed so that they can defend their position. Upon completion of the investigation, the committee will prepare an investigation report which will include any measures that are recommendation for the protection of those affected as well as disciplinary penalties, if deemed appropriate. The report will be presented to the management of the company for approval and the implementation of measures and penalties. False reports or reports that turn out to be malicious may constitute a serious disciplinary offense.

All reports are treated in confidence. In any case, the people handling the reports (anonymous or signed) are bound by the obligation to keep the identities of whistleblowers and all people mentioned in the reports strictly confidential. The identity of the whistleblower is never disclosed without his/her expressed consent to anyone other than the authorized staff members who are responsible for receiving or monitoring the reports. The same applies to any other piece of information from which the identity of the whistleblower can be deduced, directly or indirectly. Derogations from this policy apply only in accordance with the relevant provisions of the applicable legal framework.