This Code of Business Conduct has been developed taking into account the interests of the key stakeholders of ILEP S.A. and applies to all employees, officers, directors, contractors, and representatives. The Code outlines the company’s commitment to sustainability and ethical business practices and applies to all operations and business activities.

We also expect suppliers, business partners, and stakeholders of ILEP S.A. to adhere to similar standards of ethics and principles as described in this Code as well as in the Business Partners Code of Conduct. Non-compliance may lead to a review of the business relationship.

The Code complements and does not replace any local, national, or international laws and regulations. In the event of a conflict between the principles of this Code and local legislation, the stricter of the two standards shall apply, provided that it does not conflict with mandatory laws.

Each employee is responsible for reading, understanding, and complying with this Code. Violations of this Code may have negative consequences for the individuals involved and may lead to disciplinary action, up to and including termination of employment, as well as potential legal proceedings. A violation of the Code could pose financial risks to the company due to the potential cost of legal proceedings and damage to its reputation.

At ILEP S.A., we aim to be the preferred partner for all customers seeking air conditioning solutions. We will achieve this by providing high-quality, innovative products, services, and value-added solutions, while using resources in a sustainable, socially, and environmentally responsible manner.

The Management of ILEP S.A. is committed to adopting and implementing a management system designed to ensure compliance with its Code of Conduct and applicable laws and regulations, to identify and reduce relevant operational risks, and to facilitate continuous improvement.

Management’s commitment includes the following elements:

  • COMPANY STATEMENT

 

A corporate social and environmental responsibility statement confirming ILEP S.A.’s commitment to compliance and continuous improvement, which is posted in Greek in the workplace and in the quality management system manual.

  • MANAGEMENT ACCOUNTABILITY AND RESPONSIBILITY

 

Company representatives are clearly defined and are responsible for ensuring the implementation of periodic reviews and the status of ILEP S.A.’s management systems.

  • CONTINUOUS RISK ASSESSMENT & MANAGEMENT

 

Procedures for identifying environmental, health, safety, business ethics, labor and human rights risks, legal compliance risks, and risks related to its activities, determining the relative significance of each risk, and implementing appropriate procedures and controls to address identified risks. (Risk Management)

  1. Performance target setting with implementation plans and measurable indicators (KPI)
  2. Written standards, performance targets, indicators, and implementation plans, including periodic evaluation of performance against these targets.
  3. Audits and periodic assessments to ensure that ILEP S.A. and its subcontractors comply with applicable laws and regulations.
  • DOCUMENTS AND RECORDS

 

ILEP S.A. has procedures for identifying, monitoring, and understanding applicable laws and regulations as well as the additional requirements imposed by this Code of Conduct. ILEP S.A. maintains and preserves records to ensure compliance with regulations and alignment with this Code, taking appropriate confidentiality measures to protect privacy and personal data (GDPI).

  • TRAINING AND COMMUNICATION

 

ILEP S.A. has employee training programs for implementing policies and procedures and achieving improvement goals. ILEP S.A. has a process for communicating clear and accurate information regarding its performance, practices, and expectations to its employees, suppliers, and customers.

  • EMPLOYEE FEEDBACK

 

ILEP S.A. has an ongoing process for receiving feedback on procedures and practices in order to promote continuous improvement.

  • CORRECTIVE ACTION PROCESS

 

ILEP S.A. has ongoing procedures for the timely correction of any deviations identified through internal or external audits, evaluations, inspections, investigations, or reviews.

  • TRANSPARENCY

 

ILEP S.A. has procedures for the timely reporting of sustainability data in accordance with applicable local legal requirements.

The adoption of these fundamental principles by management is dynamic and not static and encourages its executives to support its mission through a continuous effort of improvement.

The Code of Conduct is based on four pillars.

I. Ethics

ILEP S.A. is committed to the highest standards of ethical behavior when interacting with employees, suppliers, and customers.

II. Environmental Protection

The management of ILEP S.A. is aware of environmental safety issues, which are an integral part of our business practices. ILEP S.A. is committed to reducing the environmental impact of its designs, production processes, and waste emissions.

III. Labor and Human Rights

The management of ILEP S.A. ensures the human rights of its employees and treats them with dignity and respect as understood by the international community.

IV. Health, Safety, and Well-being

The management of ILEP S.A. recognizes that integrating sound health and safety management practices into all aspects of its business activity is essential for maintaining high morale and producing innovative products and is committed to creating safe working conditions and a healthy work environment for all its employees.

Each pillar is analyzed as follows:

Ethics

  • BUSINESS INTEGRITY

 

ILEP S.A. does not violate any international anti-corruption convention, as well as the applicable anti-corruption laws and regulations in the countries where it operates, and does not engage in corruption, extortion, or embezzlement in any form. ILEP S.A. adheres to fair business standards in advertising, sales, and competition and maintains best business practices and high ethical standards, above all in accordance with this Code of Conduct. It ensures trust and transparency toward the businesses it collaborates with. Attempts to violate the law, forge documents, deceive, or negotiate through corruption are not accepted. ILEP S.A. avoids conflicts of interest that may undermine its credibility.

  • MINERAL SOURCING

 

ILEP S.A. avoids sourcing high-risk minerals such as Tin, Tantalum, Tungsten, Gold (the 3TGs), and Cobalt from Conflict-Affected and High-Risk Areas (as defined and recorded by the OECD). ILEP S.A. exercises due diligence regarding the origin of these minerals contained in its products throughout its supply chain and takes measures for their disposition upon request.

  • GIFTS AND HOSPITALITY

 

ILEP does not offer nor accept inappropriate benefits or benefits that could be considered as improper compensation to obtain, retain, or direct business or to secure any other improper advantage in its operations. Such inappropriate benefits (bribes, etc.) include cash, items, leisure travel, luxury meals, or services of another nature.

A benefit must meet the following requirements:

  1. The benefit must be permitted by local laws, regulations, and policies.
  2. The benefit must have a clear and legitimate business purpose.
  3. It must not be provided in exchange for any improper advantage.
  4. The nature, value, and frequency of the benefit must be appropriate for the occasion on which it is provided.
  5. The benefit must be provided in a transparent manner.
  • DISCLOSURE OF INFORMATION

 

ILEP S.A. accurately records and discloses information regarding its business activities, structure, financial status, and performance in accordance with applicable laws and regulations and prevailing industry practices.

  • PROTECTION OF REPORTING PERSONNEL & ANONYMOUS REPORTING

 

ILEP S.A. provides a complaint submission mechanism so that employees can report workplace violations and compliance breaches in accordance with local laws and regulations. The protection and confidentiality of whistleblowers are ensured, and retaliation is prohibited.

  • COMMUNITY ENGAGEMENT

 

ILEP S.A. engages with the community to promote social and economic development and to contribute to the sustainability of the communities in which it operates.

  • DATA PRIVACY, INTELLECTUAL PROPERTY, AND CONFIDENTIALITY

 

Data privacy and intellectual property rights are respected. ILEP S.A. uses confidential information appropriately, implements and maintains appropriate measures to protect the confidentiality, integrity, and availability of confidential information and personal data. The transfer of technology and know-how is carried out in a manner that protects intellectual property rights.

Environmental Protection

  • CONTROLLED SUBSTANCES MANAGEMENT AND RESTRICTIONS

 

ILEP S.A. complies with any applicable laws and regulations such as REACH and RoHS, which prohibit or restrict the use or handling of specific substances. To ensure safe handling, movement, storage, recycling, reuse, and disposal, ILEP S.A. identifies, manages, and records Substances of Concern as required and complies with applicable labeling laws and regulations for design, production, recycling, and disposal.

  • WASTE MANAGEMENT

 

ILEP S.A. manages and disposes of hazardous and non-hazardous waste generated from operations in accordance with applicable laws and regulations. Waste is stored, handled, transported, and disposed of in a manner that protects the health and safety of employees and the environment. Landfilling or incineration of waste is not permitted. Hazardous and non-hazardous waste are kept separate. Records regarding how, where, how much, and by whom waste is processed are available. Opportunities for refusal, reduction, reuse, and recycling of waste are identified and implemented.

  • WATER MANAGEMENT

 

Information is available regarding the type of incoming water used and how, where, and by whom wastewater is treated. ILEP S.A. monitors, controls, and treats municipal wastewater generated from operations before its disposal, as required by applicable laws and regulations. ILEP S.A. takes appropriate measures to prevent contamination of stormwater from its facilities.

  • AIR EMISSIONS MANAGEMENT

 

ILEP S.A. characterizes, monitors, controls, and treats air emissions from volatile organic compounds, corrosive substances, particulates, ozone-depleting chemicals, and combustion by-products generated from its operations, as required by applicable laws and regulations, prior to emission. ILEP S.A. recycles greenhouse gases.

  • SOIL POLLUTION

 

ILEP S.A. ensures compliance with applicable laws and regulations regarding soil pollution. The risk of soil pollution due to current or past activities is investigated, evaluated, and appropriate measures are taken. Environmental risks and impacts are identified and assessed to find ways to improve environmental performance. Environmental improvement plans are implemented, reviewed, and updated every 12 months. ILEP S.A. investigates and evaluates potential soil pollution risks due to past or current activities at the site.

  • ENVIRONMENTAL MANAGEMENT PERMITS & REPORTING

 

ILEP S.A. has obtained, maintains, and updates all required environmental permits (for example, emissions monitoring) and records, and complies with the operational and reporting requirements of these permits.

  • POLLUTION PREVENTION AND RESOURCE REDUCTION

 

There is no significant environmental pollution. Any incident of serious environmental pollution is reported immediately as required by law. Environmental complaints are recorded and addressed. ILEP S.A. makes efforts to reduce or eliminate wastewater, solid waste, and gas emissions, including indirect energy-related emissions and substances of concern in products, by implementing appropriate conservation measures in production, maintenance, and facility processes, and by recycling, reusing, or substituting materials. Current energy sources are known and opportunities to transition to renewable energy sources have been identified.

  • ENERGY EFFICIENCY

 

ILEP S.A. makes efforts to use energy more efficiently and to avoid energy waste by setting energy efficiency targets and monitoring power and energy consumption, adopting management practices, and switching off equipment that is not necessary in order to reduce energy consumption where possible. Energy efficiency is an important selection criterion along with quality, price, and delivery time.

  • CONSERVATION AND BIODIVERSITY

 

Business activities are not conducted in High Conservation Value Areas.

  • ENVIRONMENTAL PERMITS AND REPORTING

 

ILEP S.A. has obtained, maintains, and updates all required environmental permits (for example, effluent monitoring) and registrations and complies with the operational and reporting requirements of these permits.

  • POLLUTION PREVENTION & RESOURCE REDUCTION

 

Any incident of serious environmental pollution is reported immediately to any competent authority as required by law. Environmental complaints are recorded and addressed. ILEP S.A. seeks to reduce or eliminate wastewater, solid waste, and atmospheric pollutant emissions, including indirect energy emissions and hazardous substances in products, by implementing appropriate protective measures in its production, maintenance, and facility processes, as well as through recycling, reuse, or substitution of materials.

Current energy sources are known and opportunities to transition to renewable energy sources have been identified. ILEP S.A. recognizes that integrating effective health and safety management practices into all aspects of operations is essential for maintaining high morale and producing innovative products. ILEP S.A. is committed to creating safe working conditions and a healthy working environment for all.

  • COMMUNITY LAND RIGHTS

 

The rights and title to land and property of individuals, indigenous people, and local communities are respected. All negotiations regarding land or property, including its use and transfer, adhere to the principles of free, prior, and informed consent, contract transparency, and information disclosure.

Labor and Human Rights

  • ANTI-DISCRIMINATION POLICY

 

ILEP S.A. does not discriminate against any employee on the basis of race, color, age, gender, gender identity, sexual orientation, nationality, disability, religion, political affiliation, trade union membership, national origin, or marital status in hiring and employment practices such as job applications, promotions, rewards, access to training, job assignments, wages, benefits, discipline, and termination, nor does it require employees or job applicants to undergo medical examinations that could be used for discrimination, unless required by applicable laws or regulations or necessary for workplace safety.

  • IMPLEMENTATION OF FAIR TREATMENT

 

ILEP S.A. is committed to providing a workplace free from harassment and discrimination; it does not threaten employees nor subject them to harsh or inhumane treatment, sexual harassment, psychological or physical coercion, or verbal abuse.

  • MEASURES AGAINST FORCED LABOR & HUMAN TRAFFICKING

 

ILEP S.A. does not engage in human trafficking nor use any form of slavery, forced, bonded, subcontracted, or prison labor. Employment is voluntary, and employees are free to leave work or terminate their employment with reasonable notice. Employees are not required to surrender any government-issued documents (ID, passport, work permit) as a condition of employment.

  • MEASURES AGAINST CHILD LABOR

 

ILEP S.A. employs only workers who meet the legal minimum working age, verified by documents proving the date of birth of all its employees, and maintains a register including all such information. ILEP S.A. participates in lawful apprenticeship programs in the workplace that comply with Article 6 of the ILO Minimum Age Convention.

  • EMPLOYMENT OF MINORS

 

ILEP S.A. does not employ minors.

  • IMPLEMENTATION OF PROPER RECRUITMENT & EMPLOYMENT PRACTICES

 

Employees are not charged any fees or costs related to recruitment, employment, or termination processes. A written recruitment procedure is implemented, including rules on: age verification, evaluation, and selection of candidates. Employees sign an employment contract before starting induction training and work. Employees receive a copy of the employment contract and understand its terms before signing. Changes to employment terms are agreed upon in writing by the employee. Zero-hour contracts are not used.

Rules regarding discrimination, business ethics, disciplinary measures, and the use of tobacco and tobacco products, alcohol, and drugs are documented, implemented, and communicated to employees. Disciplinary measures do not include the use of psychological or physical violence, including corporal punishment, threats of violence, public reprimand or punishment, fines, or withdrawal of contractual benefits. Employees are free to seek assistance and have the right to challenge disciplinary decisions.

  • PROTECTION OF FREEDOM OF ASSOCIATION

 

ILEP S.A. respects the right of employees to freely associate, to form and join workers’ organizations of their choice, to seek representation, and to bargain collectively, as permitted and in accordance with applicable laws and regulations. These rights are exercised without fear of discrimination, violence, or harassment. ILEP S.A. protects against actions that interfere with the establishment, operation, or administration of workers’ organizations in accordance with applicable laws and regulations.

  • WORKING HOURS

 

ILEP S.A. applies a 40-hour workweek with two days of rest every seven days. Employees are entitled to a 30-minute break within an eight-hour shift. All extra hours and overtime are voluntary, and employees who refuse overtime are not penalized.

  • WAGES & BENEFITS

 

ILEP S.A. pays all employees at least the minimum wage in accordance with applicable laws and regulations and provides all legally mandated benefits.

Wages are paid on time, in the middle and at the end of the month. Employees receive a payslip with full details of earnings, benefits, and deductions reflecting the wages they received, and the information provided is understandable to employees.

In addition to pay for regular working hours, employees are compensated for extra hours and overtime at the premium rate required by law.

  • APPLICABLE LAWS & REGULATIONS

 

ILEP S.A. does not use wage deductions as a disciplinary measure. ILEP S.A. provides vacation time, leave, and holidays in accordance with applicable laws and regulations and maintains a transparent and reliable system for recording working hours and wages, paying employees on time and clearly explaining the basis on which payments are made. Employees are reimbursed for additional living expenses arising from work performed away from their usual place of work. Apprentices receive compensation for the work performed during their training. In addition to national insurance, ILEP S.A. provides a group insurance policy from a private company covering accidents, medical treatment for work-related injuries and illnesses resulting in permanent disability or death. ILEP S.A. provides free work clothing and personal protective equipment (PPE).

Health, Safety, and Well-being

  • PREVENTION OF OCCUPATIONAL ACCIDENTS

 

Risks to occupational health and safety, including those related to well-being and ergonomics, are assessed and measures are taken to reduce them. Employees are not exposed to serious occupational health and safety risks. Safe work procedures are implemented to minimize risks associated with hazardous tasks. Workplace accidents are reported immediately to the labor inspectorate.

Physical hazards are eliminated and, where they cannot be eliminated, ILEP S.A. provides appropriate engineering controls such as physical guards, safety switches, and barriers. Where appropriate engineering controls are not possible, ILEP S.A. has established suitable administrative controls, such as safe work procedures. Appropriate personal protective equipment (PPE) is provided in all cases within the facilities. The equipment is safe and used under safe conditions.

PPE is clean, free of charge, in good working condition, and suitable for the identified hazard. Warning signs have been posted and safety information is visible. Employees are not punished for raising safety concerns and have the right to refuse to work in hazardous conditions without fear of retaliation until management adequately addresses their concerns.

  • CHEMICAL MANAGEMENT AND PREVENTION OF CHEMICAL EXPOSURE

 

Chemicals are procured, stored, transported, handled, and used in a manner that protects the health and safety of employees and the environment. ILEP S.A. identifies, evaluates, and controls employee exposure to hazardous chemical, biological, and physical agents and eliminates chemical hazards where possible. Where chemical hazards cannot be eliminated, it provides appropriate engineering controls. When appropriate engineering controls are not possible, ILEP S.A. establishes suitable administrative controls, such as safe work procedures. In all cases, ILEP S.A. provides employees with appropriate personal protective equipment.

  • PREVENTIVE MEASURES FOR EMERGENCIES, PREPAREDNESS & RESPONSE

 

ILEP S.A. identifies and evaluates emergency situations and events to reduce their impact by implementing emergency plans and response procedures, including incident reporting, employee notification and evacuation procedures, training and drills, appropriate first aid supplies, suitable fire detection and suppression equipment, adequate exit facilities, and recovery plans.

Annual evacuation drills are conducted to test the evacuation process and identify any need for improvement. Records of evacuation drills are maintained. The evacuation signal is audible to all employees. Manual activation of the signal is possible, and alarm buttons are clearly visible and marked. Emergency routes and exits are posted and ensure quick and safe evacuation at all times. The assembly point is marked.

  • WORKPLACE HEALTH AND SAFETY PROCEDURES AND SYSTEMS

 

ILEP S.A. has established procedures and systems to manage, monitor, and report workplace injuries and illnesses that encourage employee reporting, classify and record incidents, investigate them, and implement corrective actions to eliminate their causes, provide necessary medical care, and facilitate employees’ return to work. Accidents and near-misses related to occupational health and safety are reported, analysed, monitored, and actions are taken. Records of accidents and near-misses are maintained. Safety hazards are continuously reported, analysed, monitored, and addressed.

  • ERGONOMICS

 

ILEP S.A. has established procedures to identify, evaluate, control, and reduce employee exposure to physically demanding tasks or environments, including manual material handling, heavy lifting, prolonged standing/sitting work, highly repetitive or demanding assembly tasks, high noise levels, and inadequate lighting.

  • WORKING CONDITIONS

 

The work environment is clean, hygienic, and well maintained, with adequate lighting, ventilation, and, where necessary, heating. There are areas where employees can eat and rest that are free from hazards. Toilets are free of charge, hygienic, accessible during working hours, equipped with basic supplies, and proportionate to the number of employees.

  • HYGIENE AND FOOD

 

Employees have access to clean toilets free of charge, unlimited drinking water free of charge, and hygienic facilities for the preparation, storage, and consumption of food.

  • BUILDING SAFETY AND ELECTRICAL SAFETY

 

The buildings were designed and constructed in 2024, are maintained, and modified in a way that ensures structural integrity. Electrical wiring and lighting are properly installed and maintained.

  • HEALTH AND SAFETY COMMUNICATION

 

To promote a safe working environment, ILEP S.A. provides employees with appropriate information and training on workplace health and safety, including written information and warnings in the Greek language. ILEP S.A. posts Safety Data Sheets (MSDS) for any hazardous or toxic substances used in the workplace and appropriately trains employees who may encounter such substances. Training records are maintained, including participant names, training dates, and an overview of the training content.

  • EMPLOYEE HEALTH AND SAFETY COMMITTEES

 

ILEP S.A. encourages and supports employee health and safety committees to enhance continuous training on health and safety issues and to encourage employee participation regarding workplace health and safety matters.