Ethics Code Elviplas SA

The Code of Professional ethics is our compass for daily action and operation, leads our steps based on our principles and values, determines acceptable and unacceptable behaviors among us and above all ensures the Long-term health and progress of our Organization.

Introduction

The Code of Professional Ethics (hereinafter referred to as "the Code") was designed to

The basic rules of conduct that should govern the commitment of the management to the employees as well as the professional and ethical conduct of all employees of the company Achaika Plastics S.A. (hereinafter referred to as " Company ").

The code includes the fundamental values, rules and principles that define a minimum framework for professional activities and shape the daily behavior of workers unaffected by Outstanding Interventions. This set of rules and principles describes the goal of the company's management to strengthen ethical principles and to formulate a working environment that promotes confidentiality, transparency and fair behavior.

In this code, account has been taken of:

• Quality, environment, health and safety management systems at work,

According to the standards ELOT st. ISO 9001:2015, ELOT st. ISO 14001:2015 , And SEDEX .

• The 10 principles of the UN Economic Compact (UN Global Compact), the 17 principles of sustainable development Of Un, Gr. EC.A. (Greek e-Commerce Association)
• The guidelines of the General Data Protection Regulation (regulation

2016/679), which sets the protection of personal data in the operational

Priorities.

The adoption of the Code and the harmonization with the law and the principles, creates the conditions for a long-term viable business and socially responsible course.

The code is addressed, binds and obliges all employees of the company Achaika Plastics SA and its subsidiaries, regardless of hierarchical rank and under any relationship and form of work to adhere strictly and Strictly.

It also binds our subcontractors, suppliers, partners, consultants and other business partners to adopt the values contained in the company code for as long as they cooperate with us and at the end of Cooperation.

The vision, values and principles of executive excellence of the Company

Our Vision

Our vision is to be the leading and undeniable choice of our customers in the market of supple plastic packaging and Agricultural Films. With continuous Research and Investment in the development of Technological equipment , and the exploitation of opportunities occurring in an ever-changing economic and technological environment and Our effort to find innovate packaging solution .

Our values

Teamwork and collaboration

We are joining forces with the common goal of our development. Through honest and direct cooperation we combine and utilize ideally the Technologies, the Individual skills in the best way , in collaboration with the Polytechnics and Universities of our Country for the continuous development of our products. We support each other and create a strong team with a strong sense of shared responsibility.

Respect and trust

We develop the skills and abilities of our people, we release the

Dynamism and proceed in the future in a climate of mutual trust, equality and respect. The diversity of our people and the confidence in their abilities are the driving forces for our company.

Improvement

We promote The development of smart Packaging products . In an ever-changing economic, social and technological environment, change and innovation are challenges that we respond to in the light of evolution and discrimination.

Flexibility-quality-effectiveness

We operate quickly, flexibly and effectively to respond to the challenges of the Times. We create trends and guide developments. We're always one step ahead.

The principles of Executive Excellence

Fair and Strictly

Assess and judge objectively, assuming the responsibilities of the Acts Our. We adopt a positive attitude, we lay down common rules for everyone and we exclude exceptions.

Mediocrity is not acceptable

We give our best self with professionalism, quality, efficiency. Not

We tolerate the stonewalling and do not harboring the problems. We aim at the daily Improvement by setting high standards for all.

We suggest and dare

We present our opinion clearly and with arguments. Escalating our actions in order To solve the problem (Escalation).

Preparing

We think before we act and study every sentence. We set a specific plan before each action by coordinating the teams involved and targeting them jointly.

We learn from our mistakes

Every mistake is a lesson to us and to our colleagues. We analyze our mistakes,

We share, we make useful conclusions about continuity.

We follow a structured approach

We discuss, propose and decide based on facts and figures. Weigh the consequences and act with a program.

Committed

We execute the decisions with faith and determination. We control, correct, move and apologize for the result.

We fight for the common good

The target is common. Success comes only as a result of a joint effort.

We are utilizing the available resources efficiently With new investments .Each consumption of time and money is decided by performance criteria and is associated with a specific and measurable result. We re-examine and optimize our costs continuously.

Our flag.

Profitability is our first concern to ensure the health and development of our Organization. We the long-term benefit .

We do not sacrifice the long-term benefit for the sake of temporary success, but We choose to aim high and steady, Look away and execute efficiently.

Not We're wasting our time on petty details. We focus on the important and active With common sense with a view and stability base for our company and our staff.

We respect diversity.

We share anxieties, efforts and goals, successes and failures, mistakes and victories.

We promote female entrepreneurship and belong to the Sege Greek Association Of Women Entrepreneurs.

Compliance with laws and regulatory requirements

The basic principle of the Company is respect and compliance with applicable laws,

Provisions and regulations of the State and the EU. It is the individual responsibility of all employees to be aware of the laws and regulations relating to their work and duties, and they must refrain from any activity that could involve the company or themselves in an illegal Act.

Complying with the laws is not only a moral duty. It's the only way to secure the company's interests. Any breach of the legislative framework, irrespective of its size, exposes the company to risks, the effect of which may have incalculable consequences on its economic and social position.

The executives and employees of the company are obliged to consult the Department of Legal serveZion In the event of any doubt or clarification as to the legality of their actions, in the context of the execution of their corporate duties.

In addition, the harmonization of the company with the directives of the new General Data Protection Regulation (Regulation 2016/679) lays even more solid foundations on important issues of management of personal data such as technical and organizational measures Security, data gradation, data subjects ' rights, accountability, etc.

The company provides executives and employees with the necessary training, guidance and guidance per department and role, in order to ensure the implementation of the legislative framework in practice.

Asset Protection

Employees have a common responsibility for the correct and careful handling of material (e.g. income, buildings, vehicles, machinery, furniture, goods, computers, other equipment) and intangible (e.g. studies, corporate information, Partnerships Clientele, trademarks, know-how, Patents ) pErioysias of the company as well as The intended business purposes.

The obligation to protect Intangible Property remains even when employees leave the company. Each employee has the obligation to protect the property of the company against loss, damage, misuse, risk exposure, theft, unauthorized use, embezzlement or destruction. Any situation that could lead to the risk of the company's assets must be reported by the employees without any delay to their superiors. Special attention is given to the avoidance of losses, losses, unnecessary costs or abuses of the assets of our company.

Protecting Confidential Information

The company requires its employees to keep all confidential information secure. As such, information on the company's business activities, in particular those relating to operational strategies, special agreements, financial results and other economic data and forecasts, is considered; Human Resources/customer/supplier data, information on acquisition or sale of property and equipment, business orders, Production New products, copyright and patent information, product enhancements and anything related to the company's development, know-how and financial gain.

Employees during their work in the company and beyond, must not disclose confidential information to third parties. This information must be treated as confidential and protected against unauthorized access.

In addition to the confidentiality of any employee who manages confidential information, the management of the company is responsible for the installation and protection of confidential information operation of the appropriate methods and Internal control systems and organizational measures, which should effectively ensure the timely detection of errors and their immediate resolution, in order to ensure the efficiency and efficiency of operations and Compliance with applicable laws and regulations.

If an employee has any doubts or needs clarification regarding the disposal or disclosure of information that he or she holds, he should consult the relevant departments of the company.

Our relationships with suppliers

The company and all our employees are committed to ensuring that the activities are conducted within the framework of fair competition and in strict compliance with the current European and Greek legislative framework competition.

Relations with our Suppliers Governed Throughout the range of activity from

Transparency, respect, trust, sincerity and integrity.

When selecting a partner, supplier or subcontractor, appropriate

Procedures in order to assess the adequacy of the integrity, quality, Katallilolitas and its reliability and to ensure that it possesses the know-how, ability, reliability and the requisite permission to perform the delegated activities with competence and professionalism.

It shall be ensured that all agreements with suppliers, partners and third parties are made in writing and are specified in precisely the goods and services supplied and the fees to be paid.

Information relating to pricing, customers, suppliers, competitors can only be taken by legal measures.

We are out of relationships with competitors that can be classified as illegal agreements or arrangements, such as:

• Price fixing negotiations .
• Agreements on sales shares .
• Unfair practices aimed at leading a competitor out of the market or prohibiting the entry into the market of new competitors, by non-legal means .

Our relationships with customers

Our competitive position is based solely on objective criteria such as the quality of the and innovation of our products , the integrated and reliable customer service, pricing policy, financial solvency, compliance with the basic principles of environment and security.

We build the mutual respect of our customers, And we try to know him personally, our priority is the satisfaction of there needs , and trying to contribute to the best quality of its production with our packaging. A worker who contravenes the relevant legislation on fair competition is subject to civil and criminal liability, in accordance with applicable law, as well as the relationship between his employment and the company may be terminated.

Therefore, whenever there is doubt about the legitimacy of any communication,

Agreement, commercial practice, employees must address directly to the relevant departments of the company.

Working relations

We respect and support the fundamental principles of the International Labor Organization's declaration on the Protection of labor rights. In addition, the company is an active participant (Participant) The principles of the United Nations Global Compact (UN Global Compact).

Under the United Nations Global Compact, the Company undertakes to support and implement, as part of its influence, the fundamental principles relating to human rights and labor standards.

Human rights

We respect internationally recognized human rights and take steps to identify and address any real or potential adverse effects on which we can engage through our own functions or business Our relations.

The company's policy is to operate under fair and legal human resource management procedures, without discriminate on the basis of race, religion, ethnic origin, nationality, color, gender, identity, age, nationality, Sexual orientation, marital status, disability, or any other characteristics protected by law.

The only factors to be taken into account are: experience, personality, efficiency skills of each employee.

All employees must respect the diversity of each colleague or supplier or client of the company and not accept any behavior that affects the dignity of the individual or discriminates against any Form.

Child labor

In addition, the avoidance of child, forced or illegal work is ensured. No form of coercion, imposition, exploitation or child labor It is tolerated in our company and we want the same from our partners.

Harassment

We condemn the harassment of labor relations.

We maintain the working environment free from any kind of harassment (sexual and any other legally protected category), intimidation, isolation, disrespect.

Safety and health at work

The company ensures that all employees and corporate partners employed in all its facilities work in a healthy and safe working environment.

There are a Labor doctor in all production units and In our branches and They are at the disposal of the workers. The company also works with diagnostic centers to provide all the diagnostic examinations of the employees and their families at preferential prices.

Our relations with society and the environment

H Corporate social responsibility is an integral and essential element of our strategic planning, undertaking responsible initiatives and implementing specific policies and actions regarding the improvement of the environment and society According to the principles of sustainable development and the principles of the Ecumenical Covenant of Un.

We put in our agenda as many as possible from the 17 objectives for sustainable development (Sustainable Development Goals - SDGs ) 2015 committed 193 member States of the United Nations Organization, covering issues such as poverty, gender equality, health, education, good governance, migration, climate change and environmental protection.

Social Policy

Corporate social responsibility is a key Pillar of our strategy. The triptych "Society - People - Environment ' , It's our main Think . The Company is constantly developing new initiatives and actions, reinforcing the help it offers to society, protecting the environment and strengthening and defending its people. The company's cooperation with children care and people with special needs , Updates and we help schools, The alternative management system is same of the actions we have Be adopted in the context of the sense of responsibility and respect towards society and the People .

Environmental policy

With respect and sense of responsibility towards the environment we work for the continuous improvement of our environmental performance, the minimization of the impact on the environment, the development of initiatives for the protection of the natural environment and the promotion Environmental responsibility in our culture.

The company is the first plastic industry in the European Union to implement and be certified with the environmental Iso 14001 . The first certification took place in 1999.

In addition, we maintain the following alternative management systems:

• Battery collection bins in collaboration with the left
• Collection bins Paper
• Iron Collection bins.
• Lamp collection Bins in All our production units , to save energy and reduce the volume of waste
• Recycling system Plastics in the 2 production units of Aigio and Komotini.

Alternative management System bodies we work with:

• Recycling of Appliances S.A.
• Fotokyklosi S.A.
• Aniel
• Rewarding Recycling SA
• Member of the Hellenic recycling Organization with a Number Registry producer: 1746

Ethical standards and anti-corruption

The company is committed to working with ethical business practices that Governed Transparency and reliability. In this context, employees must makes the duties Legal and ethical manner, in accordance with the applicable laws and provisions of the United Nations Convention on the Fight against corruption.

Corruption /corruption

The company in no way allows bribery, illegal payments and unfair practices. The employees of the company are not allowed to offer any kind of benefits to third parties (customers, suppliers, business partners, competitors, etc.), to receive or accept from them any benefits that may challenge the Our integrity and/or influence our business decisions.

Gifts and Donations

We do not accept gifts or offers of entertainment that may raise doubts as to our personal integrity or the independence of the company.

The employees of the company must adhere to the following principles:

• You may not request or accept gifts, benefits or offers of entertainment from third parties who have or are likely to acquire business relationships with the company. Gifts include not only material goods but also all sorts of benefits.
• They may only accept gifts or offers of entertainment that are provided to them without requesting them themselves, provided that they do not exceed the limits of comity and accepted business practices.
• The value and nature of the gift or entertainment offer must not arouse suspicion that it creates an obligation on the recipient.

We must report to the relevant Compliance department all the incidents of possible bribery or situations that could expose the company to the risk of bribery.

Relations with public officials and regulatory bodies

We must comply with all legal and contractual obligations imposed by Governments and regulatory agencies in the countries where we operate. Anyone who comes into contact with public officials and negotiates agreements is responsible for knowledge and compliance with all applicable laws and regulations.

Our contacts and relations with public officials should not endanger the reputation and integrity of our company. Particular emphasis should be placed on may be considered as a bribe on the part of the company.

We do not make any form of facilitation payment, even if this may lead to commercial delays, for example payment of small The company's application to a public authority.

If we are asked to pay a facility payment, or there are any suspicions, concerns or questions about payment, we report it to the regulatory compliance officer.

Application of the Code

This code binds all those who work in the company regardless of the time employment and from the contractual form of the contract (provision of dependent work, provision of independent services, work, Etc.) or its duration, depending on their duties and responsibilities and irrespective of their hierarchical position.

If, as part of the performance of our duties, trade with suppliers and customers we must consider the code and indicate their compliance with the rules, if required.

The code of conduct was approved and ratified by the Governing Council of the

ELVIPLAS  On 21.01.2019 And the Board of Directors of its subsidiary Elviplas SA and may be modified or cancelled only by them. Any amendments or cancellations shall be notified accordingly and The applicable code will be on the company's website .

The validity of this code begins immediately after its posting on the website of the Company.