1. Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations and to ensure that the Company's activities are conducted in a socially responsible manner.

2. Policy statement

Bribery is defined as the offering, promise, providing, accepting, or seeking advantage as an incentive for illegal action or breach of trust. It is an inducement or reward offered, promised, or provided in order to obtain any commercial, contractual, regulatory, or personal advantage.

It is the Company's policy to conduct all its activities in an honest and ethical manner. A zero-tolerance approach to bribery and corruption is adopted and there is a firm commitment to act professionally, fairly and with integrity in all its business transactions and relationships, implementing and enforcing effective anti-corruption systems, with a particular commitment to compliance with Greek laws.  Bribery and corruption carry prison sentences and fines.

3. Field of Application

3.1 Who is covered by the policy?

This policy applies to all persons working at all levels and grades, including Board of Directors, directors, employees (permanent or temporary), consultants, subcontractors, seconded personnel, casual employees, sponsors, as well as any third party working with the Company.

3.2 Bribery

Any form of bribery, direct or indirect, is prohibited, especially to public officials.

3.3 Gifts and hospitality

• It is prohibited to offer or accept gifts/hospitality that:
  • are considered illegal or unsuitable;
  • are addressed to civil servants, politicians or political parties;
  • exceed €100 per gift or €500 per hospitality (with a maximum annual limit of €1000), unless there is written approval from a Director.
• Cash gifts are not allowed.
• If it is not possible to immediately reject a gift, it must be declared and given to a charitable cause.

3.4 Facilitation payments

Payments that speed up ordinary government services are prohibited. In exceptional cases of risk, the payment must be minimal, documented and reported to the supervisor.

3.5 Political contributions

Donations to political parties or candidates are avoided in order to avoid a conflict of interest.

3.6 Charitable contributions

Legal and ethical charitable donations are allowed with compliance administrator approval and full transparency.

4. Employee Responsibilities

All employees will be informed in detail through digital means by the central administration, and are obliged to study them, understand them and adhere to the policy. Reporting a breach or suspicion is mandatory to the Compliance Administrator. Violations result in disciplinary sanctions, up to and including dismissal.

5. Record keeping

All transactions and expenses must be recorded accurately, with no "off-the-books" entries, and employees are asked to report suspicions or questions directly to their immediate supervisor or Compliance Manager, as well as to report the case directly to the Compliance Administrator if they are victims of bribery or corruption

6. Protection

Employees who refuse bribes or raise concerns are protected from any form of adverse treatment.

7. Education and Communication

Training in this policy is part of the integration and annual updating of all employees. The policy is also communicated to suppliers and partners.

8. Responsible for policy

Management is responsible for compliance and implementation of the policy, with the Compliance Officer monitoring and supporting its implementation.

9. Approval and Date of Implementation

• Policy approved by the SPARTAN Management.
• Last revision date: 29.11.24
• Next scheduled review: 28.11.27
• Version number: 2.0.

The policy is effective from the above date and is mandatory for all employees, partners and third parties involved in the management of corporate data. The policy is regularly reviewed for improvement and effectiveness.