Compliance Management System

Compliance with legislation in force, with the OTE Group Code of Conduct and the internal Policies is of great importance to us.

Ensuring Compliance is a priority for the Company's Board of Directors.
Compliance stands for a solid commitment to the principles of integrity, transparency, fairness, professionalism, team spirit, and of respect for the rules; principles which are essential to govern the operation of the Group.


To that end, the Management has adopted and implemented a Compliance Management System (CMS), regarding the compliance of all (employees and management) with the legislation in force, with the Code of Conduct and with internal Policies, aiming to avoid financial risks, legal consequences as well as reputational damage for the Group and its employees. In so doing, the benefit is for all: the Group per se, the employees, the customers, the suppliers and the shareholders.


The effectiveness of the CMS relies on the commitment and the support of both management and employees.

The Compliance Management System implemented at OTE Group is based on the international standards ISO 37001:2016 (Anti-Bribery Management Systems), ISO 37301:2021 (Compliance Management Systems), ISO 37002:2021 (Whistleblowing Management Systems) and ISO/TS 37008:2023 (Internal Investigations of Organizations Management Systems). .

Key elements of the CMS

  • Preventing misconduct and in parallel complying with the policies included in the CMS. As a result, both the Group and its employees are protected from any legal consequences due to misconduct, while potential reputational risks are reduced. Prevention is achieved mainly through:
  • Employees’ training about the risks that may arise from any violation of the applicable legal and regulatory framework, such as for example, human rights breaches, corruption incidents (e.g. fraud, bribery, etc.), falsification of accounting records and financial statements, misuse of personal data, money laundering, breach of communications privacy, as well as incidents of violence and harassment at the workplace.
  • The internal reporting channels that company employees can use in order to address questions regarding the application of the Code of Conduct and corporate Policies or receive guidance on dhttps://en/reporting-misconductaily work matters in case they are uncertain about how to deal with specific issues.
  • Detecting misconduct and responding to it. The company has established internal reporting channels for submitting reports about potential breaches of corporate policies and procedures, regulations and applicable legislation, including breaches of Union law, as laid down in article 4 of Law 4990/2022 – ‘Protection of persons who report breaches of Union law’
     

CMS Operation

The Business Unit of Head of Compliance & Enterprise Risk Management OTE Group, which is responsible for the planning and implementation of the ΟΤΕ Group CMS, reports directly to OTE Board of Directors. For the implementation of the CMS at the OTE Group, Compliance Officers have been designated at the Group subsidiary companies.


Moreover, the OTE Group Compliance, Enterprise Risks & Corporate Governance Committee has been established. The main purpose of the Committee is to support, control, and monitor the implementation of the Compliance Management System (CMS) and Risk Management System (RMS), which constitute key components of the Corporate Governance System, at OTE Group level. 
In this context, the Committee supports the competent executives on compliance, enterprise risks and corporate governance issues, reviews the periodic Compliance and Risk reports by assessing the completeness, correctness and accuracy of the relevant reports and notifies accordingly the OTE Audit Committee and the Board of Directors.


Management of Human Rights issues

Furthermore, OTE has designated on a corporate level, the Head of Compliance & Enterprise Risk Management OTE Group, as the responsible Officer for managing Human Rights issues, to whom, together with the designated persons in the group companies, internal and external inquiries as well as any relevant tip offs are addressed.

OTE Group declares that complies with the applicable laws and strives to comply with the international standards so as not to violate human rights and, to this end, it has adopted and applies the Code of Human Rights, as binding on all Group companies.

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