48 49 SUSTAINABLE DEVELOPMENT REPORT 2017 Addressing corruption and bribery is a key element of the company’s Code of Business Conduct and its Suppliers and Business Partners Code of Conduct. Also, the reference for MYTILINEOS when it comes to addressing corruption and bribery, is the principle of integrity, which relates to the company’s long- standing commitment to zero tolerance of corruption and bribery and is implemented by avoiding all transactions and contacts with any third party which may be guilty or suspect of encouraging conditions giving rise to corruption, extortion or bribery. The company’s policy on the prevention of corruption and bribery incidents is organised in three key stages: The first stage involves the analysis of prevailing conditions and potential risks or threats which may encourage the occurrence of incidents of corruption or bribery in the corporate environment. These are implemented through self-evaluations and internal audits that take place every two or three years. This particular practice covers sensitive corporate activities with a significant risk of such incidents occurring (according to international studies), such as charity contributions, sponsorships, facilitation payments, gifts and hospitality, with a view to establishing respective prevention procedures, where these are not in place. The second stage refers to ensuring that all transactions carried out on behalf of the Company by its shareholders, employees, Business Units and major business partners and suppliers, are characterised by a high level of integrity. Through established procedures, applying primarily in the Purchases-Procurement Units in connection with the selection of suppliers and other business partners, controls are carried out annually of the conditions under which every single transaction takes place, in order to identify and eliminate those which may give rise to incidents of corruption. The third stage refers to the Company’s operation as a “Responsible Corporate Citizen”, reflected in a number of voluntary initiatives such as: adherence to market rules; participation in international standards to strengthen transparency; establishing transparency as an important item on the agenda of the ongoing dialogue with its key Stakeholder groups; the provision of education and training on anti- corruption policies and procedures to its employees of all levels; and, in general, its commitment to ethical business practices and sound corporate governance. The Legal and Regulatory General Central Support Function, of which theComplianceDepartment forms part, has been entrusted with the creation and implementation of a system of safeguards to protect the company from corruption and bribery. Targets of the Material issue In 2018, MYTILINEOS aims to implement the relevant formal due diligence process whose development was completed during 2017, to safeguard the precautionary policy it applies regarding these matters. With this initiative, the company seeks to regularly assess and further improve the procedures for managing the risk of corruption, as well as to verify that the operations of its Business Sectors comply with the established corporate policies and procedures, as these are defined in the Code of Business Conduct, the Internal Regulation Code and the Suppliers and Business Partners Code of Conduct, always in full compliance with the laws and the relevant regulatory provisions in force. During 2017, MYTILINEOS applied all necessary internal procedures to safeguard its policy. The control mechanisms applied in the Purchases - Procurement Units of the company’s Business Sectors, where the selection of business partners and all types of transactions were examined, did not report or identify any circumstances that could give rise to incidents of corruption and bribery. T his management approach provides basic information to the Stakeholder groups of MYTILINEOS, so they can understand how the company manages its human capital, which makes a significant contribution to the company’s creation of added value. At the same time, by highlighting the existing positive practices, this approach works as a means of preventing any adverse effects on the completion of the company’s new operating model in the context of its restructuring. Relevance and boundaries of the Material Issue MYTILINEOS has entered a new era in its evolution, moving forward with increased prospects for growth and aiming to achieve even more ambitious goals and higher performance levels. The company acknowledges that its success is inextricably linked to the skills, experience and decision-making empowerment of each one of its employees. In line with the above, attracting and retaining capable and talented employees, investing in the development of their skills and capabilities, and encouraging them to function to the maximum of their capabilities, are the key requisite elements for the achievement of the company’s strategic business vision. In parallel, ensuring the protection of Human Rights and establishing labour relations that foster mutual trust, collaboration, two-way communication and recognition, drive personal improvement and strengthen the satisfaction of the company’s employees regarding their personal as well as their professional development. Investing in human capital is an integral part of the company’s corporate culture, as the attainment of its business goals, the achievement of positive results and its continuous growth relies on its people. Systematic investments in employee education and professional skill enhancement are key to meeting the company’s operational needs locally and internationally. Its business activity, such as metals, specialised construction projects and energy, require specific knowledge and skills which need to be constantly updated, in accordance with a framework of continuous education and training. This framework offers employees a wide range of opportunities to develop their knowledge, competences, managerial and problem-solving skills as they face new challenges every day. Through the employee performance system, MYTILINEOS ensures objectivity, transparency and meritocracy in aligning its practices with its vision, values and strategic objectives. The company can respond to risks relating to the following: the directly linked costs that may arise due to personnel voluntarily leaving the Group, the loss of valuable knowledge and experience gained through the employment and training of employees by MYTLINEOS, as well as the financial investment and the investment of time and resources that were required to train the employees. Creating opportunities for the long-term employment of skilled and talented employees does not only benefit the daily business activities of MYTILINEOS, but also helps promote the sustainable development of local communities. The results of the process for defining the company’s Material aspects showed that Human Resource Management and Development is important for all its Stakeholder groups. Boundaries: The Human Resource Management and Development framework of MYTILINEOS applies to everyone employed in its Business Sectors, while labour rights are of major significance for all employees, for the regulatory authorities and for the local communities where the company is located and operating. Major risks and relevant risk control practices: Through the operation of its Business Units, which to a significant degree are labour and HR-quality intensive, MYTILINEOS may face the following major risks: GRI 103-1 GRI 102-11 GRI 205-3 Management of the Material issue Labour practices & Human rights Performance in 2017 Disclosure Management Approach GRI 103-2 GRI 102-15