ILEP S.A. is committed to demonstrating zero tolerance toward any form of bribery, corruption, embezzlement, extortion, or undue influence.

The Policy was developed considering the interests of ILEP S.A.’s key stakeholders.

The Policy applies to all employees (staff, executives, and management) and is implemented across all functions and business activities.

This Policy is developed to address material adverse impacts related to corruption and bribery, as well as potential violations of legislation.

The Policy also incorporates related risks, such as legal disputes and reputational damage to ILEP S.A.

To achieve the above, ILEP S.A. must adhere to the following commitments:

Prohibited practices (indicative):

  • Offering / accepting money, gifts > €50,
  • Offering / accepting leisure travel,
  • Offering / accepting excessive hospitality
  • Payments to political figures or their relatives for favorable treatment
  • Use of intermediaries to “facilitate” payments

 

Rules for gifts & hospitality:

  • Maximum gift value: €50 / year / person
  • Must be transparent, documented & approved by a supervisor
  • Recording of all gifts > €20 in a register

 

Reporting mechanism:

  • Anonymous whistleblowing line: email whistleblowing@ilep.gr or tel. 210-8161219
  • Prohibition of retaliation – full protection of the reporter
  • Investigation within 30 days

 

Training & controls:

  • Mandatory annual training (at least 1 hour)
  • Periodic audits of high-risk partners

 

Sanctions:

  • Disciplinary, civil & criminal – up to dismissal & termination of partnerships

 

Governance and accountability

ILEP S.A. will establish governance mechanisms to monitor, evaluate, and manage impacts and risks arising from bribery and corruption. Responsibility for implementing this Policy lies with the senior management of ILEP S.A. These executives will ensure that bribery and corruption aspects are fully integrated into the corporate strategy and operations, with regular oversight by the Board of Directors, and that clear internal governance structures are established, including performance monitoring.

Communication and Distribution

It is the responsibility of the management of ILEP S.A. to communicate the content and spirit of this document to all personnel, direct and affiliated, and to stakeholders. This Policy is published and posted on the company’s website. To enhance awareness, ILEP S.A. will ensure that employees receive adequate training and guidance on anti-bribery and anti-corruption practices.

The Policy will be amended annually to ensure compliance with applicable laws and regulations, legal requirements, and any other relevant updates.