Compliance Management System

Compliance with legislation in force, with the OTE Group Code of Conduct and the internal Policies is of great importance to us.

Ensuring Compliance is a priority for the Company's Board of Directors.
Compliance stands for a solid commitment to the principles of integrity, transparency, fairness, professionalism, team spirit, and of respect for the rules; principles which are essential to govern the operation of the Group.

To that end, the Management has adopted and implemented a Compliance Management System (CMS), regarding the compliance of all (employees and management) with the legislation in force, with the Code of Conduct and with internal Policies, aiming to avoid risks and other legal consequences for the Group and its employees. In so doing, the benefit is for all: the Group per se, the employees, the customers, the suppliers and the shareholders.

The effectiveness of the CMS relies on the commitment and the support of both management and employees.

The Company’s CMS is reviewed by independent external auditors, who confirm the effectiveness of the procedures supporting it.

The Compliance Management System is certified in accordance with the international standard ISO 37001:2016 (Anti-Bribery Management Systems), while it has also received an attestation as per ISO 19600:2014 (Compliance Management Systems) by the independent Certification body “TUV Hellas (TUV Nord) S.A.”.

Key elements of the CMS

  • The prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the Group and its employees are protected from any legal consequences due to misconduct, while the reputational risks of the Group are reduced. Prevention is achieved mainly through:

    √ The employees’ training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, manipulation of financial statements, leakage of confidential business information, etc.
√ The channels that have been developed for the communication with employees, so that the latter can submit questions regarding the implementation of the Code of Conduct and the Policies, in case they are uncertain as to how they should handle issues that come up in their daily work.
  • The detection of compliance violations and the response to them. In order to provide the possibility of reporting any violations of Policies, regulations and of the legislation in force, the Company has established the relevant communication channels.
CMS Operation

Τhe Business Unit of Executive Director Compliance, Enterprise Risk Management & Insurance OTE Group, which is responsible for the planning and adoption of the CMS System, reports directly to the Company's Board of Directors. For the implementation of the CMS at the OTE Group, Compliance Officers have been designated at the Group subsidiary companies.

Moreover, the OTE Group Compliance, Enterprise Risks & Corporate Governance Committee has been established. The main purpose of the Committee is to support and monitor the implementation of the Compliance Management (CMS), Risk Management (RMS) and Corporate Governance Systems.

In this context, the Committee supports the Executive Director Compliance, Enterprise Risk Management & Insurance OTE Group on compliance, enterprise risk management, corporate governance and human rights issues, reviews the periodic Compliance and Risk reports by assessing the completeness, correctness and accuracy of the relevant reports and notifies accordingly the Company’s Audit Committee and the Board of Directors.

Management of Human Rights issues

Furthermore, OTE has designated on a corporate level, the Executive Director Compliance, ERM and Insurance OTE Group, as the responsible Officer for managing Human Rights issues, to whom, together with the designated persons in the group companies, internal and external inquiries as well as any relevant tip offs are addressed.

OTE Group declares that complies with the applicable laws and strives to comply with the international standards so as not to violate human rights and, to this end, it has adopted and applies the “Code of Human Rights & Social Principles”, as binding on all Group companies.
 

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