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WHISTLEBLOWING POLICY<\/u><\/strong><\/p>\n COMPLAINT<\/strong> AND<\/strong> REPORT<\/strong> MANAGEMENT<\/strong> POLICY<\/strong><\/p>\n (Law 4990\/2022, EU Directive 2019\/1937)<\/strong><\/p>\n FEBRUARY 2024<\/strong><\/p>\n The companies of NEWSPHONE group listed below (hereinafter “NEWSPHONE Group”) apply\u00a0 Greek Law 4990\/2022 and the European legislation (Directive 2019\/1937) for the protection of persons reporting or disclosing breaches of European Union law in sectors such as public contracts, product safety, protection of consumers and of the environment, financial services, network and information security, competition and personal data, corporate taxation, etc.\u00a0Indicative acts that may fall within the scope of the present Policy are offenses such as \u00a0fraud, theft, embezzlement, bribery, corruption, abuse of power, conflict of interest, breaches of confidentiality and personal data, violation of terms of service to the detriment of consumers, legalization of products of crime, breach of competition law, irregularities in matters of accounting and financial data, violations of safety and health regulations, environmental legislation, etc.\u00a0Reports of violations of Greek legislation, such as labor claims, undue discrimination, wage disparities, disciplinary matters, harassment issues in the workplace etc. \u00a0are outside the scope of the present Policy.<\/p>\n In this context, NEWSPHONE Group adopts this Complaints and Reports Management Policy (hereinafter “Whistleblowing Policy”) which is the same for the bellow-mentioned companies of the Group:<\/p>\n Who may submit a report? <\/strong><\/p>\n Persons who, in the context of their work-related activities with the aforementioned companies, acquired information pertaining to breaches of union law in the abovementioned fields.<\/p>\n More precisely: Employees of the aforementioned companies, whether engaged in full-time or part- time, permanent or temporary employment, members of the board of the aforementioned companies, shareholders,\u00a0 persons having self-employed status, consultants or remote employees, persons working under the supervision and direction of contractors, subcontractors and suppliers, persons who acquired information regarding breaches in the context of\u00a0 a work-based relationship which has since ended for any reason whatsoever (including retirement) or persons whose work-based relationship is yet to begin (in cases where information on breaches has been acquired during the recruitment process or other pre-contractual negotiations).<\/p>\n The present Whistleblowing Policy of NEWSPHONE Group pertaining to the management of Complaints and Reports, whether anonymous or non-anonymous, \u00a0aims at creating an internal\u00a0 channel for the secure and timely detection of irregularities, omissions or breaches committed by board members of the companies, employees, suppliers, possessing information for illegal acts relevant to our activities and our business in general,\u00a0 in the fields of maritime transport services, professional advertising, electronic communications and provision of value-added services and the protection of persons reporting such.\u00a0We encourage our executives, employees of any professional status, our partners, our suppliers, shareholders and any persons working under the supervision of our contractors, subcontractors and suppliers, to immediately and anonymously report cases of violations of European Union law, so that we can take the necessary corrective actions.\u00a0We adopt an internal reporting system against illegal actions, which harm our prestige, reputation, and credibility in the market and in society in general, under conditions of protection of both their anonymity and the principle of confidentiality of the reporting persons\u2019 data.<\/p>\n \u0391ny person who becomes aware of either significant irregularities, omissions, or other breaches of European Union law by the companies of the Group, their executives, employees, or suppliers, should report them, either orally or in writing, either anonymously or non-anonymously to the competent person appointed as Reporting Receipt and Monitoring Officer (Y.P.P.A.) \u00a0so as to internally adopt the lawful measures required.<\/p>\n Each report should briefly include the reason for its submission, the acts that establish a reportable incident, with specific information about persons\u2019 names, place and dates of occurrence of such illegal act, providing relevant documentation or other data. \u0399t is not necessary to include any evidence, however any relevant information which will facilitate the evaluation and investigation of the report shall be taken into account.<\/p>\n Reports are submitted, at the discretion of the reporting person:\u00a0a) either through “internal” reporting channels to each company’s competent authorized Reporting\u00a0 Receipt and Monitoring Officer (Y.P.P.A. in Greek)b) or through “external” reporting channels to the competent National Transparency Authority (E.A.D), in case the report is not investigated internally within a reasonable timeframe from its submission date<\/p>\n NEWSPHONE Group shall not pay any fee or any remuneration to the reporting person, given that the Reporting System of breaches of EU law exclusively serves the need of safeguarding the reputation, ethics and credibility of the company, its managers, shareholders, and customers, from illegal actions committed by members of the Board of Directors, executives, its staff, suppliers or partners.<\/p>\n The management of reports by the Reporting Receipt and Monitoring Officer (Y.P.P.A.) is based on the following general principles:\u00a0a) confidentiality<\/strong>: non-disclosure of the identity of the reporting person and the persons named or indicated in the report, except in cases where there is a relevant obligation by law, such as in the case of crimes prosecuted ex officiob) due diligence<\/strong>: the investigation will be carried out professionally, documenting as far as possible all findings and evidence.c) integrity:<\/strong> the research is carried out with objectivity, and without behaviors that may create suspicions of influencing the examiners.<\/p>\n In each company of the group, we have appointed a Reporting\u00a0 Receipt and Monitoring Officer\u00a0 (Y.P.P.A.), with the following responsibilities):\u00a0a) briefing \u00a0and training of personnel regarding the option\u00a0 of internal reporting .b) receiving reports of breaches of Union law.c) acknowledgment of receipt of report to the reporting person within seven (7) working days from that receipt.d) monitoring, communication with the reporting person and referral of the report to the competent bodies of the company or to the national or European bodies, as the case may be.e) completion of investigation of the report within three (3) months from its submission date.f) archiving of incomprehensible or abusive reports or reports which lack sufficient evidence or are outside the ambit of breaches as per Union law and sending notification of the relevant archiving decision to the reporting person, who has the right to resubmit the report to the National Transparency Authority (E.A.D) as an external reporting channel.<\/p>\n Should you wish to report breaches of Union law exclusively in the aforementioned areas you may use any of the alternative internal reporting channels, namely:\u00a0a) orally or through a physical meeting with the competent Reporting Receipt and Monitoring Officer (Y.P.P.A.), \u00a0b) in writing to the address of each company: 280 Thiseos Avenue, Kallithea Attikis, for the attention of the Reporting\u00a0 Receipt and Monitoring Officer (Y.P.P.A.) <\/strong>of the respective company\u00a0 NEWSPHONE HELLAS S.A., CALL CENTER HELLAS S.A., or AKEP S.A. (indicate the company concerned) in an envelope marked “Confidential”\u00a0c) by email to the electronic address of the respective company, as follows:for NEWSPHONE HELLAS S.A.: yppanewsphone@newspone.gr<\/a> for CALL CENTER HELLAS S.A: yppacallcenter@callcenter.gr<\/a>for AKEP S.A.: yppaakep@akep.gr<\/a>\u00a0d) through the electronic reporting platform https:\/\/whistleblowing.newsphone.gr<\/a> which operates on NEWSPHONE\u2019s website, also accessible to people with disabilities, that will lead you to the company\u00a0 that the report concerns .<\/p>\n A breach report that, although falling within the responsibilities of the Y.P.P.A. is nevertheless submitted to any other executive of the Group or by means other than those described above must be forwarded immediately to the competent Y.P.P.A.\u00a0 with care of the recipient.<\/p>\n1. Introduction<\/strong><\/h2>\n
2. Scope of Application <\/strong><\/h2>\n
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3. Purpose<\/h2>\n
4. Reporting mechanism for employees, executives, collaborators and content of such reports<\/strong><\/h2>\n
5. Reporting channels<\/h2>\n
6. Reports management principles<\/strong><\/h2>\n
7. Competencies of the Reporting\u00a0 Receipt and Monitoring Officer<\/h2>\n
8. Submission of report concerning a breach to the Reporting Receipt and Monitoring Officer (Y.P.P.A.)<\/strong><\/h2>\n
\u00a09. <\/strong>Reports outside standard communication channels<\/strong><\/h2>\n
10. Handling of reports<\/strong><\/h2>\n