Compliance

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.

Code of Business Conduct

As part of the continued commitment of MYTILINEOS Group to effective corporate governance, the Code of Business Conduct sets out the general principles which define the responsible business conduct and the ethical rules that all the employees throughout its operations as well as its business partners such as contractors and suppliers are expected to adhere to. The Code is of major significance for the Group, as adherence to it contributes substantially towards the attainment of the Group’s core strategic goal of Continuous and Responsible growth. The Code ensures that all Group activities taking place adhere to the principle of integrity, thus safeguarding the Group’s reputation, which is its most valuable intangible asset and, as any other asset, should not only be protected but should also be further developed, by ensuring that the conditions that will allow this are in place.

Suppliers and business partners code of conduct

As part of the continued commitment of MYTILINEOS to effective corporate governance, the Code of Business Conduct sets out the general principles which define the responsible business conduct and the ethical rules that all the employees throughout its operations as well as its business partners such as contractors and suppliers are expected to adhere to. The Code is of major significance for the company, as adherence to it contributes substantially towards the attainment of the Group’s core strategic goal of Continuous and Responsible growth. The Code ensures that all MYTILINEOS' activities taking place adhere to the principle of integrity, thus safeguarding the company's reputation, which is its most valuable intangible asset and, as any other asset, should not only be protected but should also be further developed, by ensuring that the conditions that will allow this are in place.

Compliance trainings

A crucial part of the Compliance system is the compliance related training. Trainings support the development of an ethical culture through out the entire organization. Trainings not only create awareness to the employees on the applicable legislation and the internal policies, but also offer solutions on daily business matters by detailing applicable case studies. The training objective is to help employees identify troublesome situations, to provide them with ways to get through them and in case of ambiguity to provide them with the proper escalation channel that will support them.
There are various compliance training topics the most important of which is the training on the MYTILINEOS code of conduct that includes all topics contained in the code with a deep analysis on each of them. There are two training formats, the in person training and the web based training. Although in person trainings encourage lively discussion with the instructor and may go beyond the training material, web based trainings allow the wide distribution of the material through out each country employees are located into and also provide the necessary flexibility to the employee to complete it at his/her own time plan. Training participation/ completion is tracked with the goal all employees invited to achieve completion.

Data protection policy

The protection of natural persons in relation to the processing of personal data is a fundamental right. Article 8 para. 1 of the Charter of Fundamental Rights of the European Union (the “Charter”) and article 16 para. 1 of the Treaty on the Functioning of the European Union (TFEU) provide that everyone has the right to the protection of personal data concerning him/her.

Furthermore, under General Data Protection Regulation (GDPR) No. 2016/679 of the European Parliament and the Council which came into effect on 25.05.2018, a stricter framework has been introduced for the protection of individuals with regard to the processing of their personal data and for the free movement of such data (the “General Regulation”).

The protection of natural persons with regard to the processing of personal data is of the utmost importance for MYTILINEOS (the “Company”); consequently, the Company collects and processes personal data strictly in conformance with the General Regulation and the applicable legislation in general and to the extent necessary in connection with some aspect of labor relationships and the business of the Company. The Company limits the access to such data to authorized persons only, and takes enhanced data security measures to secure data against -among others- loss, mishandling, unauthorized access, alteration or disclosure.

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Cookie policy

Cookies are small text files that a website saves on your computer or mobile device when you visit a site.It enables the website to remember your actions and preferences over a time period to provide a more user-friendly service. In addition, some cookies serve MYTILINEOS commercial advertising or/and promotion. In this section, we generally use the term "cookies" as an “umbrella term” to describe techniques such as cookies, Flash cookies and web beacons.

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CCTV data protection information

On our premises we use the closed circuit television system for the protection of persons and goods. The personal data processing is necessary for the protection of our legal rights as data controler (article 6 par.1 of GDPR)

Market Abuse Regulation: Persons discharging managerial responsibilities

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.

Business partner due diligence

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.

Whistleblowing line

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:

  • They are encouraged to report freely any activity of which they have become aware of and which deviates from the Code’s principles and may give cause for concern.
  • Such reporting is crucial for avoiding or mitigating a potential negative impact on the Company, while also supporting its culture of transparency, responsibility and integrity.
  • Reporting a violation with mention of the reporting person’s identity is more credible and at the same time allows direct communication with the person making the report, for obtaining clarifications and additional information during the report verification procedure.
  • The Management of the Company warrants that no action shall be taken against any employee who reports in good faith any actual or alleged inappropriate conduct.
  • The reporting procedure should not be abused with the submission of ill-considered accusations or personal complaints. To prevent the submission of malicious or unsubstantiated reports, sanctions may be imposed to employees who have acted in bad faith. In such cases, the laws on defamation in force in the countries where the Company operates shall apply.
  • Where employees wish to seek advice, raise a related issue or report a violation of the Code, a number of options are available. Thus, they may contact their Supervisor, Section Manager, or General Manager or communicate directly with the Company's Compliance Department.
  • Cases involving violations of the Code may also be reported by phone, fax or post, as well as by electronic mail (mentioning the reporting person’s identity or made anonymously), to compliance[at]mytilineos.gr
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