Corruption obstructs economic growth, as it can undermine fair competition and destroy trust in a company or individual. At ACTION LINE M. LTD, combating all forms of corruption is a priority, which is why the company has decided to design and install an Anti-Bribery Management System in accordance with the requirements of the International Standard ISO 37001:2016. The company’s Anti-Bribery Management System covers all of the company’s activities regarding human resources selection, assessment, and deployment services and was designed according to the needs and objectives of the Company and the Legal and Regulatory Requirements of the applicable Greek and EU Legislation.

Promoting a culture of ethics and integrity is a key factor in maintaining the trust of customers, stakeholders, and society. The company is committed to promoting a culture of integrity throughout its activities and to communicating its expectations for reducing the risk of corruption.

The company’s general objective is to fully satisfy the needs and expectations of its customers when possible and to reduce the risk of corruption. For this reason, it establishes measurable targets for corruption by seeking:

• Improvement of the organizational structure through clear delineation of powers and responsibilities.
• Compliance with legislative and regulatory provisions related to the company’s activities either directly (commercial activities) or indirectly (contractors/suppliers).
• Improvement of Internal Communication through the identification of interaction and interdependence of the company’s processes.
• Continuous improvement of the Anti-Bribery Management System and the company’s operations through effective use of the following tools:
• Setting and reviewing anti-bribery goals.
• Management Review
• Internal Audits
• Corrective Actions
• Systematic analysis of data arising from the Records.
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The company aims to prevent bribery and corruption through:

• Prohibition of facilitation payments, even when permitted by law.
• Compliance with all anti-bribery and corruption laws applicable in each country where the company operates, as well as the same requirement from contractors.
• Compliance with all global policies aimed at preventing, directly or indirectly, the risk of corruption.
• Conducting due diligence against bribery based on risks to third parties before engaging in the company’s activities.

To promote a culture of ethics and integrity, as well as compliance with all applicable anti-corruption laws and regulations, the company implements a comprehensive set of policies and standards that establish clear rules to which all its employees and, where applicable, third parties must comply. In addition to putting the company at risk, corrupt employees may be subject to civil and criminal penalties, including hefty fines and imprisonment. Additionally:

It is prohibited for the company’s employees to:

• give, promise to give, or offer any item of value to any person with the purpose of influencing any action or decision, especially in interactions with government officials. This prohibition also applies to indirect corruption, i.e., actions taken by third parties on behalf of the company. Items of value may include, among other things: money, gifts, entertainment, hospitality and meals, travel expenses, services, employment offers, loans, donations or contributions, any transfer of value, even symbolic.
• receive remuneration from a provider or customer of the company
• maintain a financial interest or relationship with a competitor, customer, or provider of the company, or any other third party doing business with the company
• engage in direct or indirect purchase or ownership of any interest in the form of real estate or property of any kind for sale or lease to the company
• engage in any external activity to such an extent that raises questions about their ability to dedicate appropriate time and attention to their duties
• interact with a relative who works for or has applied for a job with the company, a competitor, provider, or customer of the company
• make purchases of goods or services on behalf of the company from a relative or a company in which a relative has interests
• accept items of value. Accepting a gift may create a sense of obligation in the recipient, potentially undermining the objectivity of their decisions, and may be perceived as a gift intended to influence the recipient or another employee of the company.

In the company, employees are required to:

• disclose any actual or potential conflicts of interest before engaging in the transaction, activity, or relationship that gives rise to the circumstance being reported.
• disclose actual or potential conflicts of interest as part of the hiring process.
• annually disclose any actual or potential conflicts of interest if they belong to the High-Risk Employees, i.e., first-line managers and all employees of the company who are regularly involved in the creation of contracts, procurement, sales, or rental of services, materials, real estate, or products.
• abstain from participating in the board of directors of any client, provider, or competitor of the company. Participation in external board meetings, outside the professional duties of the company’s employees, is permitted only for members of the Executive Committee and must be limited to providing services consistent with their duties in the company.
• consult the respective Department Head or System Manager on how to handle a conflict of interest, rather than relying solely on their interpretation or personal judgment.

Every employee is responsible for their own work and is required to contribute to the anti-bribery management and the achievement of the established goals. For this reason, all employees, according to their responsibilities, are informed about the Anti-Bribery Management System and act demonstrably in accordance with the established rules.

Processes, flows, and actions that do not guarantee the achievement of the set goals are immediately interrupted by the responsible parties, root cause analyses are conducted, and the required improvement measures are defined.

This Anti-Bribery Policy is communicated to the staff, made available to all interested parties, and periodically reviewed by the Company’s Management.

Athens, 01/05/2020 For ACTION LINE M. LTD Management Board DS-DD07/03