Compliance Management System

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

Ensuring Compliance is a priority of the Company's Board of Directors.

Compliance stands for a solid commitment to the principles of integrity, transparency, justice, professionalism, team spirit, and of respect to the rules, principles which are essential to govern the functions of the Company.

On this purpose, 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 risks and other legal consequences for the Company and its employees. In so doing, the benefit is for all: the Company per se, the Employees, the Customers, the Suppliers and the Shareholders.

The effectiveness of the Compliance Management System relies on the commitment and the support of all: Management and employees.

The key elements of the C.M.S. are:

  • the prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the company and its personnel are protected from any legal consequences due to misconduct, while the reputational risks of the company are reduced. Prevention is achieved mainly through:
    • the employee's training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, the manipulation of financial statements, leakage of confidential business information, etc.
    • the channels that have been developed for the communication with employees, so that the latter can submit questions regarding the implementation of the Code of Conduct and the Policies, in case they are uncertain as to how they should handle issues that come up in their daily work.
  • the detection of compliance violations and the response to them. In order to provide the possibility of filing a tip – off regarding violations of Policies, regulations and of the legislation in force, the Company has established the Whistleblowing Policy and the relevant communication channels. In the context of this Policy, employees or/and third persons may nominally or namelessly report to the    Compliance Office a tip – off or express a concern or a complaint regarding potential violations of the Company's Policies or the legislation. The Company does not allow for any retaliation act on behalf of the management or other bodies of the Company, directly or indirectly against any person, who on good will, reports or expresses concern or complaint with regards to violation of policies or law.

Τhe Compliance Officer responsible for the planning and adoption of the CMS, reports directly to the Company's Board of Directors. 

The OTE Group Compliance, Enterprise Risks & Corporate Governance Committee has been established with main purpose to support and monitor the implementation of the Compliance Management (CMS), Risk Management (RMS), Corporate Governance Systems and human rights issues of the Group.

The CMS applied at OTE Group is reviewed by independent external auditors, who confirm the effectiveness of the procedures which support it.

OTE Group Code of Conduct

The key to our Group of companies' success lies in the adoption of a corporate culture with common values and rules of conduct within and outside it, which is characterized by integrity, ethics and personal responsibility. In this context, the OTE Group Code of Conduct has been adopted. 

Our Code of Conduct is the framework for guiding the behavior of all people in the OTE Group of companies. Specifically, the Code confirms our commitment to consistently comply with the laws and regulations governing the operation of the OTE Group of companies as well as with the requirements relating to ethical behavior, and supports the success of our Group.

Being part of the OTE Group and sharing the corporate identity requires that each and every individual accepts personal responsibility. A single incident of misconduct can damage not only the Group's success, but also the good reputation acquired through the commitment demonstrated by our people on a daily basis.

Our Code of Conduct is applicable to all people who work at OTE Group companies, worldwide: from Board members and Managing Directors to Executives and Employees. It also equally applies to Consultants and individuals whose work is the functional equivalent of that performed by Group Employees.

Compliance Policies

In the context of implementation of the Compliance Management System, the following Policies and Codes are in force:

OTE Group Code of Conduct

The Code of Conduct is the framework for guiding the behavior of all people in the OTE Group of companies. Specifically, the Code confirms our commitment to consistently comply with the laws and regulations governing the operation of the OTE Group of companies, as well as with the requirements relating to ethical behavior, and supports the success of our Group.

OTE Group Policy on Avoiding Corruption and other Conflicts of Interest

This Policy provides the framework for avoiding corruption and other conflicts of interest in relationships with customers and business partners. 

OTE Group Whistleblowing Policy

The Whistleblowing Policy provides a description of the rules and the basic guiding principles with regard to the handling of tip-offs related to violations of Company Policies, Regulations or current legislation.

OTE Group Code of Ethics for Senior Financial Officers

This Code defines the framework of conduct of the Senior Financial Officers, in order for honesty, integrity, transparency and ethical conduct by those persons to be promoted in the performance of their management responsibilities.

Binding Corporate Rules Privacy

These rules contain the necessary requirements for the processing of personal data in accordance with applicable Greek and European legislation and ensure the high level of protection of personal data.

OTE Group Policy on Insider Trading

The Policy on Insider Trading describes the responsibilities and obligations of the employees of OTE Group regarding the Inside Information.

OTE Group Policy on Anti-Trust Law

The Policy on Anti-Trust Law describes the operational framework in the context of antitrust law for the activities of OTE Group of Companies and its employees. It sets down corresponding operational guidelines for employees who conduct discussions or negotiations with competitors, suppliers or customers that have the potential to restrict the competitive freedom of action of OTE’s Group of Companies, its contractual partners or third-party companies.

OTE Group Donation Policy

The Donation Policy defines the specific transparent and mandatory procedures to be followed by OTE Group companies when assessing and implementing Donations, based on the action areas defined by the Sustainable Development strategy.

OTE Group Sponsoring Policy

The Sponsoring Policy describes how to deal with Sponsorship issues by setting out clear criteria for implementing the procedure which needs to be followed by the OTE Group companies in order to carry out Sponsorships, ensuring transparency regarding the efficient use of resources allocated for Sponsorships.

OTE Group Policy on Accepting and Granting of Benefits

This Policy provides a description of the rules and regulations of conduct with regard to the acceptance and offering of benefits in business dealings.

OTE Group Anti-Fraud Policy

The Anti-Fraud Policy provides a description of the rules and the basic guiding principles with regard to the fraud incidents that may occur at OTE Group companies and it sets the necessary measures for the prevention of such fraud cases.

OTE Group Event Policy

This Policy describes the basic conditions, principles and rules of conduct to be observed in the conception, planning, execution and monitoring of events.

OTE Group Policy on Avoiding Sexual Harassment within OTE Group

Target of this Policy is the prevention of sexual harassment acts, the awareness of managers and employees in relation with this issue, and the enhancement of confidence of employees regarding the support they shall have by their superiors in such cases.

Policy on Employee Relations within OTE Group

This policy specifies the key elements of employee relations within OTE Group. It describes what we stand for in our relationship with employees in all countries where we operate.

OTE Group Corporate Responsibility Policy

This Policy sets out the strategy and the action plans of the Corporate Responsibility for OTE and its affiliates, taking into consideration the social and financial circumstances as well as the culture priorities and challenges.

OTE Group Social Charter

In OTE Group Social Charter, the Basic Social Principles are mentioned which the Company is committed to observe and apply wherever it operates and guarantees to notify its stakeholders and suppliers.

OTE Group Supplier Code of Conduct

Based on the Company core values addressing business ethics, social and environmental commitments, the Company requires the Suppliers to adhere to the listed, at the Code, Principles, which will be attached to the contract entered between the Company and the Supplier. The Supplier shall do its utmost to implement these Principles through its whole supply chain.

Whistleblowing Channels

Fight Corruption - Submit Complaints

Tip offs regarding serious infringement of the Company’s policies and procedures and of the applicable laws (e.g. corruption, abuse, theft, money laundering, falsification of financial statements, non-compliance with OTE Group Code of Conduct and/or Policies, human rights issues and any misconduct which could harm the company's reputation, or any attempts to conceal the above), are handled based on the approved OTE Group Whistleblowing Policy.

Under this Policy, employees or/and third persons may nominally or namelessly report to the Compliance Office violations of policies / procedures of the Company or applicable laws.

Tip offs are handled according to a confidential procedure. Before submitting a tip-off, please consider the consequences that it may have on the persons involved.

The Company does not allow for any retaliation act on behalf of the management or other bodies of the Company, directly or indirectly against any person, who on good will, reports or expresses concern or complaint with regards to violation of policies or law. The protection of the whistleblower from any action of retaliation is an important provision of the Whistleblowing Policy, unless the tip-off is malicious and, thus, no protection provision is applied.

If your tip off refers to specific individuals, these are entitled, in the context of exercising the rights to information, access and objection according to the Articles 11-13 of Law 2472/1997 as in force, and, consequently, to be informed about it and any relevant evidence.

We note that if your tip off refers to individuals, it should not contain elements which are sensitive personal data (i.e. data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health, social welfare and sexual life, criminal prosecutions or convictions).

Communication channels for complaints:

Please do not use these channels for any issues relevant with products or services provided by the Company. These issues should be directed only to Company's Customer Service.

  • Electronic Whistleblowing form
  • Via Mail:
    Hellenic Telecommunications Organization S.A. (OTE S.A.)
    OTE Group Compliance Office,
    99 Kifissias Ave., 15124 Maroussi, Athens, Greece
    OR
    Hellenic Telecommunications Organization S.A. (OTE S.A.),
    OTE Group Compliance Office,
    P.O. BOX 61368 / GR-15104 Maroussi, Athens, Greece
  • Via e-mail:
    whistleblowing@ote.gr
    tellmecompliance@ote.gr
  • Via telephone:
    +30 210 611 2345 (Monday through Friday: 9am until 5pm)
  • Via Fax:
    +30 210 611 6790
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