{"id":5811,"date":"2024-03-27T16:04:36","date_gmt":"2024-03-27T14:04:36","guid":{"rendered":"https:\/\/www.elvidafoods.gr\/?page_id=5811"},"modified":"2024-03-27T16:25:18","modified_gmt":"2024-03-27T14:25:18","slug":"reporting-policy","status":"publish","type":"page","link":"https:\/\/www.elvidafoods.gr\/en\/reporting-policy\/","title":{"rendered":"Reporting Policy"},"content":{"rendered":"\t\t
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<\/p>

REPORTING POLICY<\/b><\/center>
<\/center>

<\/p>\n

DECEMBER 2023 <\/b><\/p>\n

Scope of application <\/b><\/p>\n

ELVIDA FOODS S.A.<\/p>\n

Date of validity <\/b><\/p>\n

17.12.2023<\/p>\n

Version <\/b><\/p>\n

1.0<\/p>\n

Approval <\/b><\/p>\n

Board of Directors<\/p>\n

Categorization <\/b><\/p>\n

Politics\/Policy<\/p>\n

Power Level <\/b><\/p>\n

Binding\/Binding<\/p>\n

    \n
  1.  INTRODUCTION :<\/b><\/li><\/ol>\n

    \u201cELVIDA FOODS SA\u201d’ has taken the necessary measures to ensure good corporate<\/p>\n

    governance and compliance with all the regulatory obligations governing its operation. To this end,<\/p>\n

    the Company has drawn up and adopted the Reporting Policy (hereinafter the “Policy<\/b>“), which<\/p>\n

    provides general guidelines and instructions regarding the management of, inter alia, reports of<\/p>\n

    violations of European Union law.<\/p>\n

    The Company encourages all those referred to herein to report, confidentially or<\/p>\n

    anonymously through existing reporting channels, conduct that is illegal or unethical, as soon as it<\/p>\n

    comes to their attention. Failure to report may in some cases constitute a criminal offence where there<\/p>\n

    is a legal or contractual obligation to do so. All reports will be taken seriously and investigated with<\/p>\n

    full objectivity and independence. The Company assures that those who make reports will be<\/p>\n

    protected from any retaliation and that the personal data of all parties involved are protected by<\/p>\n

    applying the necessary technical and organisational security measures. The Reporting Policy is<\/p>\n

    adapted to the principles and provisions of Law 4990\/2022 “Protection of persons reporting <\/i><\/p>\n

    violations of EU law – Implementation of Directive (EU) 2019\/1937 of the European Parliament and <\/i><\/p>\n

    of the Council of 23 October 2019 (L 305) and other urgent provisions”<\/i>. <\/b><\/p>\n

      \n
    1.  PURPOSE :<\/b><\/li><\/ol>\n

      The purpose of the Reporting Policy is to:<\/p>\n

      \u03b1) To define the principles and framework for reporting within the Company.<\/p>\n

        \n
      1. b) Encourage the reporting of incidents that have taken place in the Company related to<\/li>\n<\/ol>\n

        violations of EU law in the areas of public procurement, financial services, products and markets,<\/p>\n

        prevention of money laundering, financing of terrorism, product safety and compliance, transport<\/p>\n

        safety, environmental protection, radiation protection and nuclear safety, food and feed safety, and<\/p>\n

        the prevention of money laundering; 2 of Article 26 of the EU Treaty, including infringements of<\/p>\n

        Union competition and State aid rules, as well as infringements relating to the internal market<\/p>\n

        concerning acts in breach of the rules on corporate taxation or arrangements the purpose of which is<\/p>\n

        to secure a tax advantage that frustrates the object or purpose of the applicable corporate tax<\/p>\n

        legislation.<\/p>\n

          \n
        1. c) To provide assurance that reports and investigations of incidents are handled in complete<\/li>\n<\/ol>\n

          confidentiality, that the personal data of the parties involved are protected and that those who report<\/p>\n

          will be protected from retaliation.<\/p>\n

            \n
          1. d) The application of Law 4990\/2022 and the international and European best practices<\/li>\n<\/ol>\n

            applicable to company reporting in accordance with the OECD and the European Union.<\/p>\n

              \n
            1.  TERMS :<\/b><\/li><\/ol>\n

              Report: the oral or written provision of information regarding violations of this policy.<\/p>\n

              \u03b1) “Internal report”: the verbal or written provision of information on violations to the<\/p>\n

              Company’s Receiving and Monitoring Officer (RMO\/YPPA).<\/p>\n

              (b) “External reporting” means the provision of information on violations to the National<\/p>\n

              Transparency Authority (NTA) orally or in writing or through an electronic platform.<\/p>\n

              Inadmissible Report (or inadmissible Report): a Report that refers to a violation that does<\/p>\n

              not fall within the scope of this Agreement, or a Report that is not clear, definite, complete, timely or<\/p>\n

              is manifestly malicious, frivolous\/excessive and repetitive.<\/p>\n

              Reporting party: a person who reports or discloses information about violations obtained in<\/p>\n

              the course of his or her work.<\/p>\n

              Retaliation: Any direct or indirect act or omission that occurs in an employment context as<\/p>\n

              a result of an internal Petition and that causes or is likely to cause undue harm to the Petitioner.<\/p>\n

              External partners: Third parties contractually linked to the Company and their personnel,<\/p>\n

              namely consultants, subcontractors, contractors, suppliers, suppliers, mall retailers, partners of all<\/p>\n

              kinds, shareholders, etc.<\/p>\n

              Committee for the Management and Evaluation of Petitions (hereinafter referred to as the<\/p>\n

              “CMP”\/EDDA): The three-member committee charged with the management and investigation of<\/p>\n

              petitions.<\/p>\n

              Employee: a person who contracts with the Company under any contract or employment<\/p>\n

              relationship, as well as a person who is a seasonal employee or a person employed as a trainee by the<\/p>\n

              Company.<\/p>\n

              Reporting channels: The channels through which reports are submitted and include the<\/p>\n

              means used to submit reports and the persons to whom the reporters can be addressed.<\/p>\n

              Malicious Report: A Report that is made with the Petitioner’s knowledge that it is not true.<\/p>\n

              Receiving and Monitoring Officer: the Receiving and Monitoring Officer (YPPA) for reports<\/p>\n

              of violations falling within the scope of this Agreement.<\/p>\n

                \n
              1.  APPLICATION FIELD :<\/b><\/li><\/ol>\n

                \u03b1) Subjective scope of application <\/b><\/p>\n

                The Reporting Policy applies to persons who report information about violations obtained<\/p>\n

                in the course of their work, i.e. to members of the Board of Directors, Directors and staff of the<\/p>\n

                Company, regardless of the type of contract or employment relationship that links them to the<\/p>\n

                Company (employment contract\/service contract, trainees, seasonal staff, job candidates, consultants,<\/p>\n

                self-employed, etc.).<\/p>\n

                The scope of protection of this Policy also includes third-party contractors of the Company,<\/p>\n

                suppliers, consultants, consultants, partners of any kind, under project contracts, independent<\/p>\n

                services, paid assignments, persons employed through third-party contractors of the Company,<\/p>\n

                persons attending training, including trainees and apprentices (whether paid or unpaid), persons<\/p>\n

                whose employment relationship has been terminated for any reason, including retirement, and persons<\/p>\n

                whose employment relationship has not been terminated for any reason, including retirement, and<\/p>\n

                persons whose employment relationship has been terminated.<\/p>\n

                A condition of inclusion in the scope of protection of this policy is that the report is made in<\/p>\n

                good faith, i.e. those making the report have reasonable grounds for believing that the information<\/p>\n

                they provide is true. In all cases, good faith shall be presumed unless it can be shown that the<\/p>\n

                Reporting was made in bad faith. In the event of a malicious report, it goes without saying that the<\/p>\n

                protection described in this policy is not afforded.<\/p>\n

                (b) Objective scope <\/b><\/p>\n

                Reports of irregular, unethical, illegal or criminal conduct in connection with the Company’s<\/p>\n

                operations include: 4 \/ 12<\/p>\n

                Gonata 40, 121 33 Peristeri, Greece<\/p>\n

                Tel. +30 210 5785051<\/p>\n

                Fax +30 210 5785052<\/p>\n

                Violations of the applicable legal and regulatory framework, violations of the Company’s<\/p>\n

                Operating Regulations, Code of Conduct, Regulations, Policies and Procedures, criminal acts, acts<\/p>\n

                that endanger public health, acts that endanger the protection of the environment, acts that endanger<\/p>\n

                the health and\/or safety of employees, shareholders, members of the Board of Directors, executive<\/p>\n

                and non-executive, executives, members of the Committees, external collaborators, members of the<\/p>\n

                Board of Directors, members of the Board of Directors and external collaborators.<\/p>\n

                PRINCIPLES: <\/b><\/p>\n

                The principles underlying the Reporting Policy are the following:<\/p>\n

                ANONYMITY: A central and integral principle of the policy is the protection of the<\/p>\n

                anonymity and confidentiality of the personal data of each petitioner.<\/p>\n

                EXCEPTION: In the case where the petitioner participated in the event and bears part of the<\/p>\n

                responsibility, he is not relieved of his consequences and responsibilities. However, the report and<\/p>\n

                his\/her contribution to the detection and investigation of the illegal acts will be taken into account in<\/p>\n

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

                claims against those responsible and the company’s judicial approach.<\/p>\n

                EQUALITY: All reports are in principle treated equally by the CAA and the NCA, regardless<\/p>\n

                of the origin or the act complained of.<\/p>\n

                TRANSPARENCY: The reporting process also aims to enhance the transparency of<\/p>\n

                corporate action and strengthen the company’s regulatory compliance.<\/p>\n

                PROTECTION: The bona fide reporter is not subject to retaliation, regardless of the validity<\/p>\n

                or outcome of his\/her report, and is protected from any reactions of the persons complained about.<\/p>\n

                However, if the reporting party has acted in a malicious manner or with the intention of causing harm<\/p>\n

                or unlawful interference with the rights of wrongfully accused persons or third parties, then the rights<\/p>\n

                of the latter are protected.<\/p>\n

                CONFIDENTIALITY: The Company provides all guarantees to ensure that the reporting<\/p>\n

                process respects the confidentiality conditions as specified by this Policy, the Company’s Privacy<\/p>\n

                Policy and the applicable national and European legislation, both with regard to the content of the<\/p>\n

                report and any information that may lead to the identification of the person disclosing it. Personal<\/p>\n

                data and any kind of information that may lead, directly or indirectly, to the identification of the<\/p>\n

                reporting party, shall not be disclosed to anyone other the authorized persons who are competent to<\/p>\n

                receive, monitor and investigate the reports, i.e. beyond the three members of the Report Management <\/p>\n

                and Evaluation Committee, the Y.P.P.A., any qualified external consultants specifically called upon<\/p>\n

                to investigate the incident, unless the Reporting Party has given express consent or the Report is found<\/p>\n

                to be malicious. To this end, the Company shall take appropriate technical and organisational<\/p>\n

                measures, such as pseudonymisation techniques, when submitting, receiving and monitoring the<\/p>\n

                Report and when communicating with the competent authorities, if deemed necessary. In any case,<\/p>\n

                during the investigation of an incident, the identity of the Reporting Party shall not be disclosed to<\/p>\n

                anyone else.<\/p>\n

                INVESTIGATION CONFIDENTIALITY: The Hellenic Statistical Authority and the NCA<\/p>\n

                must maintain confidentiality and protect the confidentiality of information that comes to their<\/p>\n

                attention in the course of the investigation.<\/p>\n

                  \n
                1. SUPPORT <\/b><\/li>\n<\/ol>\n

                  Ms Dimitra Giatagana has been appointed as the Receiving and Monitoring Officer (RMO\/YPPA).<\/p>\n

                  The Management and Evaluation Committee is composed of 3 members and 3 alternates:<\/p>\n

                  Regular members:<\/p>\n

                    \n
                  1.  <\/li>\n<\/ol>\n

                    Sofia Politsou<\/p>\n

                      \n
                    1.  <\/li>\n<\/ol>\n

                      George Karamanolis<\/p>\n

                      iii.<\/p>\n

                      Christina Papachristou<\/p>\n

                      Alternate members:<\/p>\n

                        \n
                      1.  <\/li>\n<\/ol>\n

                        Yianna Karamitsa<\/p>\n

                          \n
                        1.  <\/li>\n<\/ol>\n

                          Petros Lykas<\/p>\n

                          iii.<\/p>\n

                          Asimenia Karagianni<\/p>\n

                          In case the report concerns one or more members of the Management and Evaluation<\/p>\n

                          Committee (EDAA), the YPPA limits itself to registering the report in the relevant register of reports<\/p>\n

                          and forwarding it to the National Transparency Authority as an external reporting channel, informing<\/p>\n

                          the reporter.<\/p>\n

                            \n
                          1.  EXTERNAL CONSULTANTS :<\/b><\/li><\/ol>\n

                            Where necessary and depending on the scope of the investigation, additional professional<\/p>\n

                            support will be obtained from external partners, such as legal advisors, external auditors, fraud <\/p>\n

                            investigators and specialised experts. At the end of the investigation, the external consultants may<\/p>\n

                            suggest and assist in the establishment or improvement of policies, procedures and controls where<\/p>\n

                            these have been inadequate.<\/p>\n

                            The external consultants should be highly qualified and should not have a relationship with<\/p>\n

                            any natural or legal person which could constitute a conflict of interest. External consultants may<\/p>\n

                            have access to the information, provided that appropriate safeguards, such as a Confidentiality and<\/p>\n

                            Data Protection Agreement, are in place.<\/p>\n

                            The involvement of external consultants\/experts is necessary in some cases for the following<\/p>\n

                            reasons:<\/p>\n

                            – They have the required knowledge, skills and experience in specialised subjects.<\/p>\n

                            – They can reach firm conclusions as to the investigation of individual items, ensure the<\/p>\n

                            legality of the process, the completeness of the evidence and the speed, in order to<\/p>\n

                            avoid as much as possible the obstruction of the Company’s business operations due<\/p>\n

                            to the audit.<\/p>\n

                            – They have the necessary independence and neutrality to ensure that the outcome of<\/p>\n

                            their investigation enjoys greater credibility with shareholders, investors, public<\/p>\n

                            bodies, independent authorities or other third parties.<\/p>\n

                              \n
                            1.  COMPLIANCE WITH THE POLICY – DUTY TO COOPERATE :<\/b><\/li><\/ol>\n

                              All those referred to in the scope of application must comply with this Policy and cooperate<\/p>\n

                              with the RMO\/Y.P.P.A., the E.D.A.A. and their authorised partners in the conduct of the internal<\/p>\n

                              investigation, as non-cooperation will make the work of the investigation extremely difficult.<\/p>\n

                              Employees shall be bound as to their obligation to comply and cooperate by explicit contractual terms<\/p>\n

                              contained in the employment contract. And external collaborators are bound by written contracts that<\/p>\n

                              include specifically worded terms that they accept the Company’s policies and procedures, including<\/p>\n

                              this policy, under which they must cooperate. An employee’s direct or indirect refusal to<\/p>\n

                              comply\/cooperate with an internal investigation may result in disciplinary action. At the beginning<\/p>\n

                              of the interview, employees and external partners are informed, inter alia, of the consequences of non\u0002<\/p>\n

                              compliance and non-cooperation at the investigation stage.<\/p>\n

                                \n
                              1.  CENTRAL REGISTER OF REFERENCES:<\/b><\/li><\/ol>\n

                                EDAA shall maintain a common electronic and physical archive that includes copies of all<\/p>\n

                                notices related to the collection and retention of data as well as copies of documents, data, information<\/p>\n

                                and all evidence, interview transcripts, the investigation report and decisions of the supervisory<\/p>\n

                                bodies. The file shall meet all technical security requirements and shall be accessible only to<\/p>\n

                                authorised persons involved in the investigation work.<\/p>\n

                                  \n
                                1.  REFERENCE CHANNELS :<\/b><\/li><\/ol>\n

                                  The Company has arranged for the establishment of multiple reporting channels for persons<\/p>\n

                                  wishing to submit reports. Any of the above mentioned persons who suspect that any of the above<\/p>\n

                                  misconduct is being committed shall first address in person or by telephone or email to their<\/p>\n

                                  immediate supervisor or manager. If he\/she has any concerns (e.g. if he\/she fears retaliation or<\/p>\n

                                  suspects the involvement of his\/her supervisor or manager), he\/she may address any of the three<\/p>\n

                                  members of the Management and Evaluation Committee or the Management and Evaluation<\/p>\n

                                  Committee as a body (EDAA), or directly to the Receiving and Monitoring Officer (YPPA). The<\/p>\n

                                  above also applies when the petitioners are not employees of the Company.<\/p>\n

                                    \n
                                  1. GUIDELINES FOR REPORTING : <\/b><\/li>\n<\/ol>\n

                                    \u0391) The Report should be made in good faith and without delay, as soon as it becomes<\/p>\n

                                    apparent. It is clarified that “without delay” means reports that take place:<\/p>\n

                                    (i) within a period of twelve (12) months from the time when matters of a financial nature or financial<\/p>\n

                                    impact (e.g. contracts, tendering procedures, negotiations, etc.) become known;<\/p>\n

                                    (ii) within a period of six (6) months from the time issues with no economic dimension or economic<\/p>\n

                                    impact (e.g. incidents of conduct, discrimination, harassment, etc.) become known;<\/p>\n

                                      \n
                                    1. B) The Report should be clear, defined and contain as much information and detail as<\/li>\n<\/ol>\n

                                      possible in order to facilitate its investigation.<\/p>\n

                                        \n
                                      1. C) The Report should include the name of the person (or persons) who may have committed<\/li>\n<\/ol>\n

                                        misconduct, the date\/time period and place where the incident took place, the type of misconduct and<\/p>\n

                                        as detailed a description as possible.<\/p>\n

                                          \n
                                        1. D) The Petitioner need not be absolutely certain of the validity of his\/her Petition. He should<\/li>\n<\/ol>\n

                                          not take illegal actions that may put himself, the company or a third party at risk in order to seek and<\/p>\n

                                          collect more evidence to support his Report.<\/p>\n

                                            \n
                                          1. E) The Petitioner should be available, either confidentially or anonymously, to provide<\/li>\n<\/ol>\n

                                            further information upon request. In particular in the case of an anonymous Petition, the Petitioner<\/p>\n

                                            may choose to be available through any other specific communication route or specific point of<\/p>\n

                                            contact (at the Petitioner’s sole discretion).<\/p>\n

                                              \n
                                            1. RESPONSIBILITIES FOR THE RECEIVING AND MONITORING OFFICER <\/b><\/li>\n<\/ol>\n

                                              OF REPORTS <\/b><\/p>\n

                                              YPPA has the following responsibilities:<\/p>\n

                                              (a) provide appropriate information on the possibility of reporting within the Company and<\/p>\n

                                              communicate the relevant information in a prominent place within the Company,<\/p>\n

                                              (b) receive reports of violations falling within the scope of this Agreement,<\/p>\n

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

                                                take up the report,<\/p>\n

                                                (e) ensure that the confidentiality of the identity of the reporter and any third party named in<\/p>\n

                                                the report is protected by preventing access to it by unauthorised persons,<\/p>\n

                                                (f) monitor the reports and maintain communication with the petitioner and, if necessary,<\/p>\n

                                                request further information from the petitioner,<\/p>\n

                                                (g) provide information to the petitioner on the actions taken within a reasonable period of<\/p>\n

                                                time, which shall not exceed three (3) months from the acknowledgement of receipt, or if no<\/p>\n

                                                acknowledgement has been sent to the petitioner, three (3) months from the expiry of seven (7)<\/p>\n

                                                working days from the submission of the report,<\/p>\n

                                                (h) provide clear and easily accessible information on the procedures under which reports<\/p>\n

                                                may be submitted to the National Transparency Authority and, where appropriate, to public bodies<\/p>\n

                                                or institutions, bodies, offices or agencies of the European Union,<\/p>\n

                                                  \n
                                                1. i) designs and coordinates training activities on ethics and integrity, participates in the<\/li>\n<\/ol>\n

                                                  development of internal policies to enhance the integrity and transparency of the Company.<\/p>\n

                                                    \n
                                                  1. j) seeks specialised and experienced internal or external collaborators depending on the<\/li>\n<\/ol>\n

                                                    needs of the research and cooperates with the EDAA.<\/p>\n

                                                      \n
                                                    1. RESPONSIBILITIES OF THE COMMITTEE FOR THE MANAGEMENT <\/b><\/li>\n<\/ol>\n

                                                      AND EVALUATION OF REPORTS : <\/b><\/p>\n

                                                      The management of the reports submitted through the Reporting Channels is carried out by<\/p>\n

                                                      EDAA, which has the following responsibilities:<\/p>\n

                                                        \n
                                                      • Review the admissibility of reports that come to its attention from all of the Company’s established<\/li>\n<\/ul>\n

                                                        reporting channels.<\/p>\n

                                                          \n
                                                        • Evaluate and prioritise reports.<\/li>\n
                                                        • Communicate with the Petitioner, when foreseen.<\/li>\n
                                                        • It shall take all appropriate measures to protect the personal data of the subjects involved in the<\/li>\n<\/ul>\n

                                                          reports and shall ensure their erasure in accordance with the time limits laid down.<\/p>\n

                                                            \n
                                                          • It shall keep a Central Register of Reports.<\/li>\n
                                                          • It cooperates with Y.P.P.A.<\/li>\n<\/ul>\n
                                                              \n
                                                            1. PROTECTION OF PETITIONERS : <\/b><\/li>\n<\/ol>\n

                                                              The Company protects those who report in good faith, illegal or unethical conduct. In this<\/p>\n

                                                              context, any kind of negative behaviour against anyone who has made a Report is prohibited, even if<\/p>\n

                                                              the Report is proven to be, as a result, incorrect. In particular, the Company is committed that<\/p>\n

                                                              employees who have made a Report will not suffer retaliation, harassment or marginalisation,<\/p>\n

                                                              intimidation or threats and unfair treatment as a result of their Report, (e.g. dismissal, unfounded<\/p>\n

                                                              negative evaluation, denial of leave, exclusion from training courses, denial of expenses, etc.). Also,<\/p>\n

                                                              unjustified changes in the employment relationship as a result of the Referral are not permitted (e.g.<\/p>\n

                                                              dismissal, suspension, demotion or deprivation of promotion, reduction in salary, change of<\/p>\n

                                                              workplace, relocation, diversification of duties, change in working hours, etc.). In the case of a<\/p>\n

                                                              malicious reference, the above protection does not apply.<\/p>\n

                                                              The same level of protection applies to third parties connected to the petitioners who could<\/p>\n

                                                              be retaliated against in a work context, such as colleagues or relatives of the petitioners. Where the <\/p>\n

                                                              Petitioner is an external contractor, early termination or cancellation of a contract for goods or<\/p>\n

                                                              services as a result of the Petition is not permitted.<\/p>\n

                                                              Any retaliatory action should be reported directly to, investigated and resolved by EDAA. If<\/p>\n

                                                              the investigation reveals that retaliation has indeed occurred, disciplinary action will be taken against<\/p>\n

                                                              the perpetrator. The person accused of having committed the retaliation has the burden of proving<\/p>\n

                                                              that his\/her actions are not related to the Report made by the employee (reversal of the burden of<\/p>\n

                                                              proof).<\/p>\n

                                                              In the event that an employee decides to make a Report regarding an incident covered by<\/p>\n

                                                              this policy in which he\/she was previously involved, the fact that he\/she eventually reported it will be<\/p>\n

                                                              taken into account in his\/her favour in any other subsequent proceedings (e.g. disciplinary<\/p>\n

                                                              proceedings).<\/p>\n

                                                              In case the reporting employee expresses the wish to be provided with special protection<\/p>\n

                                                              from any retaliation (e.g. transfer to another department), the Company will consider the possibility<\/p>\n

                                                              of satisfying the relevant request within the existing possibilities.<\/p>\n

                                                              In case the Report is made by name and after investigation it is proven that the Company has<\/p>\n

                                                              protected vital financial or other interests of the Customer, the person who made the Report will be<\/p>\n

                                                              rewarded in the most appropriate way possible.<\/p>\n

                                                                \n
                                                              1. RIGHTS OF THOSE MENTIONED OR INCLUDED IN THE REFERENCE : <\/b><\/li>\n<\/ol>\n

                                                                The Petitioner has the right to be informed both of the receipt of his\/her Petition (within 7<\/p>\n

                                                                working days at the latest) and of the outcome of the investigation (within 3 months at the latest). The<\/p>\n

                                                                way of being informed is specified in the Reporting Policy. Investigations are carried out in complete<\/p>\n

                                                                confidentiality and with respect for confidentiality at every stage of the procedure, as far as possible,<\/p>\n

                                                                in order to avoid stigmatisation and victimisation of individuals. Individuals included in reports have<\/p>\n

                                                                the right to be called to account. The identity of the Petitioner shall remain confidential. Exceptionally,<\/p>\n

                                                                if the report is found to be malicious, and if the complainant so requests, he or she may be informed<\/p>\n

                                                                of the identity of the reporting party in order to exercise his or her legal rights. It is clarified that<\/p>\n

                                                                Reports which are proven to be patently malicious will be further investigated at the Company’s<\/p>\n

                                                                discretion both as to the motives and the parties involved in order to restore order by all lawful means<\/p>\n

                                                                and methods.<\/p>\n

                                                                  \n
                                                                1. CORRECTIVE ACTIONS AND DISCIPLINARY SANCTIONS : <\/b><\/li>\n<\/ol>\n

                                                                  Depending on the results of the investigation, EDAA recommends corrective or<\/p>\n

                                                                  disciplinary\/legal actions. These actions may include (but are not limited to) (a) additional employee<\/p>\n

                                                                  training, (b) establishing new internal controls, (c) modifications to existing policies and\/or<\/p>\n

                                                                  procedures, (d) disciplinary sanctions including permanent removal\/dismissal, or (e) and legal action.<\/p>\n

                                                                    \n
                                                                  1. PERSONAL DATA : <\/b><\/li>\n<\/ol>\n

                                                                    Any processing of personal data under this policy is carried out in accordance with the<\/p>\n

                                                                    national and European legislation applicable to personal data and the Company’s privacy policy. The<\/p>\n

                                                                    data of all parties involved are protected and processed solely and exclusively in relation to the Report<\/p>\n

                                                                    in question and for the sole purpose of verifying the validity or otherwise of the Report and<\/p>\n

                                                                    investigating the specific incident. Sensitive personal data and other data not directly related to the<\/p>\n

                                                                    Report shall not be taken into account and shall be deleted. Only those involved in the management<\/p>\n

                                                                    and investigation of the incident may have access to the data contained in the reports. Personal data<\/p>\n

                                                                    shall be deleted within a reasonable period of time from the completion of the investigation initiated<\/p>\n

                                                                    on the basis of the Report. Personal data will be deleted from the Report Register from material<\/p>\n

                                                                    obtained during the investigation in accordance with the timeframes set out in the Report<\/p>\n

                                                                    Management Policy.<\/p>\n

                                                                      \n
                                                                    1. INFORMATION AND TRAINING ON REPORTING POLICY : <\/b><\/li>\n<\/ol>\n

                                                                      The Company ensures that all its employees are informed and trained on the content of this<\/p>\n

                                                                      Policy. The information is provided through the sending of informative material, emails, newsletters<\/p>\n

                                                                      or other appropriate means depending on the category of employees. Information about the policy is<\/p>\n

                                                                      also posted in a prominent place on the Company’s website. Training (face-to-face or online) is<\/p>\n

                                                                      provided on a regular basis.<\/p>\n

                                                                      The external partners are contractually bound to provide relevant information to their staff.<\/p>\n

                                                                      This will be done according to the instructions and with the help of material provided by the Company<\/p>\n

                                                                      and by any appropriate means, such as email, sending information material, etc. The information and<\/p>\n

                                                                      awareness-raising activities should be disseminated internally.<\/p>\n

                                                                        \n
                                                                      1. SUBMISSION OF AN EXTERNAL REPORT: <\/b><\/li>\n<\/ol>\n

                                                                        In addition to the internal report, there is also the possibility of submitting an external report<\/p>\n

                                                                        to the National Transparency Authority (NTA), which acts as an external body. The submission of a<\/p>\n

                                                                        Report to the N.A.D. can be made in writing, orally or via the N.A.D.’s online platform. Details on<\/p>\n

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

                                                                        https:\/\/aead.gr\/submit-complaint.<\/p>\n

                                                                          \n
                                                                        1. COOPERATION WITH COMPETENT AUTHORITIES : <\/b><\/li>\n<\/ol>\n

                                                                          To the extent that the report relates to violence and harassment within the meaning of articles<\/p>\n

                                                                          3 and 4 of Law 4808\/2021, the Company shall ensure cooperation and provide any relevant<\/p>\n

                                                                          information to the competent authorities, upon request.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/section>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"

                                                                          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  INTRODUCTION : \u201cELVIDA FOODS SA\u201d’ 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…<\/p>\n","protected":false},"author":1,"featured_media":2039,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"my-templates\/template-fullwidth.php","meta":{"footnotes":""},"class_list":["post-5811","page","type-page","status-publish","has-post-thumbnail","hentry"],"acf":[],"yoast_head":"\nReporting Policy - Elvida Foods<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.elvidafoods.gr\/en\/reporting-policy\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Reporting Policy - Elvida Foods\" \/>\n<meta property=\"og:description\" content=\"REPORTING POLICY DECEMBER 2023 Scope of application ELVIDA FOODS S.A. 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