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 financial risks, legal consequences as well as reputational damage 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 Compliance Management System is certified with the international standards ISO 37001:2016 (Anti-Bribery Management Systems), ISO 37301:2021 (Compliance Management Systems) and ISO 37002:2021 (Whistleblowing Management Systems) by an independent certification body, regarding compliance with the Standards’ requirements and the effectiveness of the implemented procedures.
Key elements of the CMS
- Preventing misconduct and in parallel complying with the policies included in the CMS. As a result, both the Group and its employees are protected from any legal consequences due to misconduct, while potential reputational risks are reduced. Prevention is achieved mainly through:
√ Employees’ training about the risks that may arise from any violation of the applicable legal and regulatory framework, such as for example, human rights breaches, corruption incidents (e.g. fraud, bribery, etc.), falsification of accounting records and financial statements, misuse of personal data, money laundering, breach of communications privacy, as well as incidents of violence and harassment at the workplace.
√ The internal reporting channels that company employees can use in order to address questions regarding the application of the Code of Conduct and corporate Policies or receive guidance on daily work matters in case they are uncertain about how to deal with specific issues.
- Detecting misconduct and responding to it. The company has established internal reporting channels for submitting reports about potential breaches of corporate policies and procedures, regulations and applicable legislation, including breaches of Union law, as laid down in article 4 of Law 4990/2022 – ‘Protection of persons who report breaches of Union law’.
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
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.
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.