MYTILINEOS, as a responsible business citizen, fully integrates in its activity the regulatory framework defined by both Greek and European legislation, as well as the international forums in which it participates.
According to the Market abuse Regulation and the Hellenic Capital Market Commission, Persons discharging managerial responsibilities in MYTILINEOS, as well as persons closely associated with them, shall notify MYTILINEOS and the Hellenic Capital Market Commission on their transactions regarding MYTILINEOS securities within a three day period.
Compliance retains a catalogue of all persons discharging managerial responsibilities, that includes persons/ legal entities closely associated with them, and informs them regularly about their obligations and the blackout periods before the announcement of the financial results.
MYTILINEOS expects that all its partners hold similar standards of integrity when acting on its behalf. For this reason MYTILINEOS has established a detailed process of business partner compliance due diligence for certain types of cooperations.
The business partner is actively cooperating with MYTILINEOS and provides all necessary documentation/ information, as required, before any contractual agreement is made. After the collection process has been completed a Compliance Officer is checking the due diligence for completion and remaining red flags and sends the recommendation to the responsible Manager that shall approve or decline the cooperation. Any cooperation is then monitored for red flags during its duration.
The Company expects its employees to report serious violations of the Code of Conduct, when they become aware of them or when these are brought to their attention. This will allow the Company to address and rectify the matter – ideally, before it becomes a violation of the law or a health and safety risk or jeopardises the Company’s reputation. In cases involving violations of the Code, the competent bodies of the Company shall investigate thoroughly the reports made, while at the same time observing the confidentiality of the relevant information, unless otherwise provided for by the law.
The Company’s employees must be aware of the following: