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 in conjunction with the Guiding Principles it 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
The following Policies and Codes apply in the context of implementing the Compliance Management System:
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 in conjunction with the Guiding Principles it 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 Diversity, Equity & Inclusion Policy
This Policy promotes the values of Diversity, Equity & Inclusion in the workplace (DE&I).
Policy on the Prevention and Combating of Violence and Harassment at the Workplace
This Policy outlines the framework for managing any form of violence and harassment at the workplace in accordance with Law 4808/2021 for the Protection of Employment.
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 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 Sustainability Policy
The Policy sets out the OTE and its affiliates’ sustainability/ ESG management approach and the framework of the overall action plan implemented by the Group, taking into consideration current and future economic, social and environmental conditions, priorities and challenges.
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.
Policy on Concluding Transactions with Related Parties
This Policy describes the method with which the Company handles issues regarding transactions with Related Parties, in compliance with current legislation.
Digital Ethics Guidelines on Artificial Intelligence OTE Group
Digital Ethics Guidelines on Artificial Intelligence OTE Group, set the rules that we need for the work of our developers and designers and for when we collaborate with suppliers and partners. They also provide legal certainty when it comes to the handling of AI products and services. Εach and every guideline is a statement and a promise: for taking on responsibility, for transparency, for data privacy, security, for self-determination in terms of data and for consumer protection.
Incidents of Misconduct
You may report incidents regarding violations of company Policies, Procedures or applicable laws (e.g. fraud, corruption, theft, embezzlement, money laundering, falsifying accounting records and financial statements, non-compliance with the OTE Group Code of Conduct, or/and Policies, issues relating to human rights and in general, any act or omission which could harm the Company or its reputation) by using the communication channels mentioned below:
Please do not use these channels for any issues relevant with products or services provided by the Company. These issues should only be directed to Company's Customer Service.
Employees or third parties who provide information on wrongdoing or violations of corporate Policies, as well as employees or third parties mentioned or included in those tip-offs shall have the right to obtain access to the personal data, to obtain information as to whether or not personal data concerning him or her are being processed, shall have the right to object, to obtain rectification of inaccurate personal data, as well as to request at any time and without charge the erasure of personal data they have provided under the terms of the General Data Protection Regulation (EU 679/2016-GDPR).
The Compliance Office is committed to collect and maintain only data that is necessary in accordance with the principle of proportionality, to delete them safely after a period of five (5) years, unless there are serious grounds for their maintenance (e.g. ongoing investigations, pending court proceedings), to protect the personal data data from loss, misuse, unauthorized access or disclosure, and generally to ensure that there are appropriate technical and organizational measures that guarantee data protection.
The collection and processing of personal data is performed with confidentiality by the responsible employees who have received special training for this purpose.
Moreover, the Company shall take all necessary measures to guarantee that persons, who provide information on incidents regarding violations, in good faith and having reasonable grounds to believe that the information provided is reliable, do not suffer any personal, business or pecuniary loss. On the contrary, employees who deliberately raise false and malicious allegations shall not be protected.
Finally, it is noted that the Company has established clear rules and Policies which define what is allowed and what incidents constitute misconduct. These incidents have consequences for offenders and specific sanctions and penalties are imposed.