Compliance Management System

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

Ensuring Compliance is a priority for 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 operation of the Company.

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

The OTE Group Compliance Management System applied by the Company is based on the international standards ISO 37301:2021 (Compliance Management Systems),  ISO 37001:2016  (Anti-Bribery Management Systems) and ISO 37002:2021 (Whistleblowing 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 Company 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 daily 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

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.

Management of Human Rights issues  

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 & Social Principles", as binding on all Group companies. and has in place the communication channel humanrights@ote.gr for relevant issues.

Furthermore, OTE has designated on a corporate level, the Executive Director Compliance, ERM and Insurance 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.