Introduction

ERGATIKAT acts in accordance with this Code of Ethics. ERGATIKAT requires all those who work, collaborate or in any way contract with the company such as its Employees, Executives, Top Management, Suppliers and Customers (hereinafter Contracted Parties), to comply with the Principles stated below. The Contracting Parties with ERGATIKAT must make every effort to implement these Principles throughout the supply chain. The purpose of ERGATIKAT’s Code of Ethics is not to replace the laws and regulations in force in any country in which ERGATIKAT operates, but to promote and comply with these laws and regulations, and ensuring their systematic and effective application. This set of rules and principles describes the behavior we expect from our people, as well as the way we conduct our business with customers , our suppliers and other partners.

Principles

Integrity

We respect the country’s laws and regulatory framework, as well as international commitments and corporate responsibility initiatives, and act with a high sense of responsibility and ethics. We recognize the obligation we have to operate safely, protect the environment and support the local communities in which we operate. We invest and actively contribute to improving the quality of life for everyone, inside and outside the company.

Commitment

We pride ourselves on and take personal responsibility for achieving high-quality results while building long-term relationships with our customers and suppliers. We focus on the health and safety of our people and provide a work environment that motivates our employees to be productive, result-oriented, and manage their personal improvement with zeal and integrity.

Focus on Results

We focus on achieving high standard solutions for our clients, efficiently and reliably. We demonstrate determination and confidence in our ability to maximize productivity and business excellence while maximizing shareholder value.

Technological Advancement and Innovation

We focus on technological expertise in order to continuously achieve high-quality results and value-added solutions. We develop an environment of continuous learning and invest in Research and Development, state-of-the-art technologies, modern equipment and know-how in order to promote innovative ideas so that the Group is constantly ahead.

Team spirit

We pride ourselves on working as a team and collaborating, supporting each other to achieve common goals, whether as team members or team leaders. We choose to work as a team, making the most of everyone’s skills, ideas and opinions. We all work for the benefit of the Group and we all feel co-responsible.

Meritocracy

We act with fairness and transparency in all our relationships. We recognize people’s personalities and abilities and place them in the position where they will contribute to the greatest extent and can be recognized. We constantly think, act and communicate with consistency and integrity.

1. Compliance with National and European Law

In addition to complying with the provisions detailed in Paragraphs 1 to 6 below, the Contracted Parties must comply with all applicable laws, regulations and contractual obligations agreed between ERGATIKAT and the Contracted Parties. These include the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, as applicable. In addition, the Contracting Parties shall comply with any international trade sanctions (including embargoes) which include sanctions imposed pursuant to a resolution adopted, in accordance with Chapter VII of the Charter of the United Nations, by the Security Council of the United Nations, and the sanctions that may have been imposed by the European Union.

The Parties agree that the implementation of the Code of Conduct of ERGATIKAT constitutes a basic contractual obligation. The Contracting Parties will bind their partners, contractors and/or subcontractors to observe the Principles of the ERGATIKAT Code of Conduct.

2. Human rights

The Contracting Parties must respect internationally recognized human rights and avoid involvement in the violation of human rights of any kind. The Parties must respect personal dignity and privacy and the rights of each individual. Forced labor and slavery in all its forms is prohibited. In addition, the Contracting Parties must comply with all the standards established by the International Labor Organization (ILO).

3. Social Responsibility

3.1 Freedom of Association and Right to Collective Bargaining

The Parties must ensure the implementation of internationally recognized standards, e.g. ILO Conventions, without violating national legislation. They must ensure that their employees and their representatives including temporary workers (through a temporary employment agency), express themselves openly in their company regarding issues related to working conditions.

3.2 Child Labor

Child labor is strictly prohibited. The term “Child labor” is in accordance with the definition of the International Program on the Elimination of Child Labor (IPEC) of the ILO and Article 32 of the United Nations Convention on the Rights of the Child (United Nations Nations Convention on the Rights of the Child – UNCRC). In the event of an incident of child labor on the premises of the Parties, the Parties shall take immediate remedial measures in accordance with the best interests of the child.

3.3 Diversity and Non-Discrimination

The Contracting Parties must prohibit discrimination based on race, colour, sex, sexual orientation, language, religion, political or any other beliefs, national or social origin, property, birth or any other status, and promote diversity, equal opportunities or equal treatment in employment and work. The Contracting Parties shall treat all employees with respect and shall not use physical punishment, mental or physical coercion, any form of abuse or the threat of such treatment.

3.4 Remuneration

The Parties shall provide pay as defined by national minimum wage law and avoid wage reductions as a disciplinary measure. In the absence of national law defining the above, the pay must be sufficient to satisfy basic needs (ILO C131 – Minimum Wage Fixing Convention). Employees must be paid on time. The Parties shall not use salary reduction as a disciplinary measure.

3.5 Working hours

Hours of work, including overtime, must comply with applicable local laws. In the absence of a national legal standard, the ILO standards will apply. The Contracting Parties shall respect each employee’s need for rest and ensure that each employee is entitled to adequate paid leave.

3.6 Health and Safety

The Contracting Parties must provide their employees with a safe and healthy workplace and implement effective programs, when deemed necessary, to improve the working environment. The Contracting Parties must make every effort to control the risks and take the necessary preventive measures for accidents and occupational diseases. The Contracting Parties must provide adequate and regular training to ensure that employees are trained in health and safety matters. The training will include the provision and instructions for the use of appropriate personal protective equipment. The Contracting Parties must ensure that, when housing is provided, the environment will be clean, safe and will meet the basic needs of workers and, where applicable, their families. The Contracting Parties are encouraged to implement a Health and Safety Management System based on international standards such as OHSAS 18001 or similar.

4. Responsible Environmental Practices

4.2 Natural Resources and Waste Management

The Contracting Parties must limit the use of materials and resources, including water, during the supply or production of products in order to reduce their environmental impact. The Contracting Parties are encouraged to trace the source of supply of minerals from war zones, promote transparency throughout the supply chain and implement measures to this end and to limit or avoid the use of scarce resources where possible. The Contracting Parties must identify, monitor and manage the waste produced by all its activities and take care of its reduction. Waste management should be in accordance with current legislation.

5. Prohibited Business Practices – Anti-Corruption Policy

The following is a summary of the business practices we do not allow, do not tolerate and expressly prohibit.

5.1 Corruption

Any corrupt practices are expressly prohibited. We do not tolerate corruption, money laundering, bribery or other unethical or illegal activity. Our performance and competitiveness are developed exclusively and only through legal practices. The Contracting Parties must refrain from any form of corruption or actions, which could possibly be interpreted as such. The Contracting Parties may not offer, promise or grant illegal benefits to national or international public officials or private sector decision-makers in order to obtain preferential treatment or a favorable decision in their favor.

5.2 Gifts and Donations

The same applies to donations, gifts or invitations to business lunches and events. It is strictly forbidden to accept gifts, donations that can question our integrity or appear to influence our professional decisions. Similarly, the Contracting Parties are not allowed to request benefits.

5.3 Donations to Political Parties

The Contracting Parties are not allowed to make monetary donations or assign monetary benefits to political parties as long as this is prohibited by law.

5.4 Sponsorships

In the context of Corporate Social Responsibility, we make donations for social and humanitarian reasons or in order to support social actions that promote education, culture, sports and sound environmental behavior. All sponsorships on the part of the Contracting Parties must be in accordance with the applicable legislation.

All sponsorships, gifts and donations on the part of ERGATIKAT must be offered transparently and in accordance with the Code of Ethics and must not be offered to a Party with whom we are or are about to be in any type of negotiation. All sponsorships on the part of ERGATIKAT are approved by the Managing Director of ERGATIKAT only if the recipient of the sponsorship has undergone a previous criminal record and/or solvency check.

5.5 Competition

The Contracting Parties must respect the rules of free and fair competition in all business relationships, and in particular will not act against any fair competition and/or antitrust legislation.

5.6 Money Laundering

We do not tolerate any kind of activity that may be related to money laundering or illegal financing. The Contracting Parties must take all measures to prevent money laundering within their sphere of influence.

5.7 Conflict of Interest

Employees and members of the Board of Directors must conduct their personal and any other external activities in such a way that does not conflict or does not appear to conflict with the interests of the Group. In the event that a conflict of interest issue arises, a report should be made immediately by the person involved to his/her immediate supervisor.

In addition, all employees must inform their supervisor of any relationship with individuals or companies with which the Company has business dealings that could lead to a conflict of interest. These relationships include blood or blood ties, cooperation or investment.

5.8 Security and Data Protection

The Contracting Parties must comply with all applicable data protection laws and all specific requirements on data protection and security agreed in our agreements.

6. Compliance

All employees, managers and other persons acting on behalf of the Company are expected to comply with the applicable legal framework and rules and to observe the imposed restrictions. All employees are personally responsible for complying with the law and the Code of Ethics. To ensure compliance we inform every high-ranking executive as well as employees in a position of responsibility through intra-company individual or small-member sessions.

The Contracting Parties undertake, and require their board members, officers, employees, suppliers, subsidiaries, subcontractors and any representatives to respect the rules of Paragraph 5.

In order to ensure compliance with this Code of Conduct, the Contracting Parties are required to provide, upon request, all the required data documenting compliance and to immediately inform ERGATIKAT, when they become aware of or, for any other reason, become aware of non-compliance of any Contracting Party with the Authorities, as well as to inform about all corrective measures taken to ensure compliance with the Authorities. Indications of non-compliance are filed through the communication channel for whistle blowers compliance@ergatikat.gr.

All Parties are encouraged to immediately report any concern, indication or evidence of non-compliance with this Code of Conduct, and are assured that their identity and report will remain confidential and the Contracting Party will be protected by ERGATIKAT in the event of negative consequences or retaliation from the report non-compliance.

In the event of a modification of the legal and/or regulatory framework and any court decision related to a violation of the Principles by any of the Contracting Parties, ERGATIKAT may introduce relevant amendments, which the Contracting Parties must comply with. If not covered in the Contract, the following applies to Social, Environmental and Regulatory Compliance Audits: ERGATIKAT and/or its authorized representative has the right to audit the Contracting Parties, in order to effectively assess their compliance with the Principles. In this context, ERGATIKAT and/or its authorized representative has the right to carry out checks, including on-site inspections, questionnaires and/or interviews with selected workers at the Contracting Parties’ facilities, at construction sites and/or at other locations where work is carried out part of the Parties.

The Contracting Parties acknowledge that ERGATIKAT has the right to request and receive further information, if deemed necessary. At the request of ERGATIKAT, the Parties shall inform ERGATIKAT of the measures taken to ensure compliance with the Principles. In case of non-compliance with the Principles, any non-compliance will be notified to ERGATIKAT and a special improvement plan will be developed which must be implemented within a specific schedule.