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 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 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) and ISO 37001:2016  (Anti-Bribery Management Systems).

Key elements of the CMS.

  • the prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the Company and its employees 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, 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 reporting any violations of Policies, regulations and of the legislation in force, the Company has established the relevant communication channels.

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  

Code Of Human Rights And Social Principles

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.

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 [KEA2] 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.

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:

Electronic Whistleblowing form
Via e-mail:
whistleblowing@ote.gr
tellmecompliance@ote.gr
E-mail: humanrights@ote.gr ,  for concerns or complaints regarding human rights’ violations (this does not exclude the use of the other channels)
Via telephone:
+30 210 611 2345 (Monday through Friday: 10am until 5pm)

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


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.

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)