INTRODUCTION

EUROPEAN DYNAMICS group of companies (hereinafter the “Company“), with offices in Greece, Germany, the United Kingdom, Belgium, Luxembourg, Austria, the Netherlands and Switzerland, adopts this report management policy (hereinafter the “Policy“), adapted to the new regulatory requirements (European Directive 1937/2019 as incorporated into national legislations), aiming to strengthen transparency and integrity in its corporate environment, to adopt appropriate corrective measures and to protect employees and third parties, but also the Company’s own interests.

In the context of this Policy, the Company encourages its employees and/or third parties to report irregularities that have come to their attention or to express any concerns regarding potential violations of the Company’s policies or of the wider regulatory framework that governs its operation. The Company establishes a system of internal or external reporting of irregularities that may occur within the Company, in a confidential or anonymous manner. Also, the Company appoints a person responsible for ensuring the receipt and monitoring of potential reports, in accordance with applicable legislation, as well as a team that will manage them, in order for the person who reports them to not risk his/her relationship with the corporate bodies and to be protected from possible retaliation by the affected persons, but also to ensure the protection of the personal data of all parties involved.

DEFINITIONS

In the context of this Policy, the following definitions apply:

• Report: the verbal or written provision of information about violations within the Company.
• Reporting person: the person (natural and not legal entity), employee of the Company (with any kind of employment contract), related to the Company or a third party, who reports or discloses information about violations, which information he/she[i] obtained in the context or on the occasion of his work, cooperation or relationship with the Company. In particular, reporting persons can be:

– the employees, i.e. those who provide their services and receive remuneration for them, regardless of whether their employment is full or partial, permanent or seasonal, current and former employees of the Company,

– the shareholders and persons belonging to the Company’s administrative bodies, including non-executive members, managers or supervisory bodies (regardless of whether they are paid),

– third parties contractually linked to the Company, e.g. consultants, tenderers, contractors, subcontractors, suppliers and all kinds of partners.

• Person concerned: the natural or legal person named in the report as the person to which the violation is attributed to or who is related to the person to whom the violation is attributed to.
• Breaches: acts or omissions related to any of the following matters:
• breaches of EU law in the areas of public procurement, financial services, products and markets, as well as the prevention of money laundering and financing of terrorism, security and compliance of products with EU and national regulatory provisions and directives; transport safety, protection of the environment, protection from radiation and nuclear safety, food and feed safety, animal health and welfare, public health, consumer protection, privacy and personal data protection, as well as the security of network and information technology systems,
• breaches affecting the financial interests of the European Union, in accordance with Article 325 of the Treaty on the Functioning of the European Union (TFEU), i.e. acts related to fraud or any other illegal activity against the financial interests of the Union.
• internal market-related infringements as referred to in Article 26(2) of the TFEU, including infringements of Union competition and state aid rules, as well as internal market-related infringements relating to acts in breach of company taxation rules or arrangements the purpose of which is to secure a tax advantage which cancels the subject-matter or purpose of the applicable legislation on corporate taxation.
• “PRMR”: the Person in charge of Receiving and Monitoring Reports regarding violations that fall within the scope of this Policy. (PRMR)
• Report Management Committee (RMC): competent body for the management and investigation of the report.
• Good faith: the reporting person’s belief that the information he/she reports is true.
• Retaliation: any direct or indirect action, omission or threat, which takes place in a work context as a consequence of a report and which causes or is likely to cause the reporting person undue harm or disadvantage.
• Conflict of Interests: any situation in which the impartial performance of the duties of the PRMR or member of the RMC is affected.

REPORT SUBMISSION PROCEDURE

Any interested party can submit his/her report to the PRMR by e-mail to the following address: whistleblowing@eurodyn.com .

After the submission of a report, the PRMR confirms its receipt to the reporting person within a period of seven (7) working days from the day of receipt. The PRMR can end the procedure by archiving the report, if it is incomprehensible or is submitted abusively or does not contain incidents that document a violation that falls within the scope of this policy or there are no serious indications of such violation, and communicate the relevant decision to the reporting person.

The PRMR will take all the necessary actions in order for the competent bodies of the Company to be engaged with the report that needs assessment, i.e. the Report Management Committee (RMC), which has been set up for this purpose.

The PRMR and the RMC should perform their duties with integrity, objectivity and impartiality, they should respect and follow the rules of secrecy and confidentiality for the matters they became aware of during the exercise of their duties and abstain from the handling of specific cases, if there is a conflict of interests.

Whenever deemed necessary, persons who can assist in the investigation of the report, due to their special knowledge, may be included in the procedure, provided that they undertake in writing to respect the confidentiality of the procedure and the information which they will become aware of.

The PRMR should provide information to the reporting person about the actions taken within a reasonable period of time, which does not exceed three (3) months from the confirmation receipt, or if no confirmation has been sent to the reporting person, three (3) months from the end of seven (7) working days from the submission of the report.

During the investigation of the report, the PRMR may call the reporting person for further information. Upon completion of the investigation, the RMC concludes to its relevant report, which is communicated to the heads of the departments involved and the Company’s Management, in order to be decided whether and what measures will be taken. Indicatively, these measures include a) further training of staff and third-party partners, b) amendments of corporate policies, c) disciplinary sanctions, d) legal actions.

The Company maintains a record of the reports that have been submitted and all related documents, respecting in any case the confidentiality requirements. The reports are stored for a reasonable and necessary period of time, in order for them to be recoverable and for the Company to comply with the requirements imposed by this policy and the relevant legislation and in any case until the completion of any investigation or judicial process that has been initiated as a consequence of the report against the reported person, of the reporting person or third parties.

CONTENT OF THE REPORT

The violation report should be made in good faith and without delay, once it becomes known to the reporting person. The report should be clear, definite and include as much information and details as possible, in order to make it easier to be investigated. It should include at least the details of the person who may have committed an offence, the date and place of the alleged incident, the type of offense (at the judgment of the reporting person) and as detailed a description as possible. Personal data and other information that are not related to the reported incident and therefore do not serve the investigation of the issue, should not be included in the report, and if they are included, they will be deleted by the PRMR.

The report can be anonymous, however submitting a named (always confidential) report grants the opportunity to communicate and provide further information if deemed necessary.

It is not necessary for the reporting person to be completely certain in order to file a relevant report, as long as he/she has reasonable suspicions or concerns. However, any intentional report of false or malicious information is prohibited and may result in taking measures and sanctions.

REPORTING PERSON’S PROTECTION

The Company guarantees the confidentiality of each report and of the information included therein, even in case the report proves to be unfounded. The details of the reporting person will not be disclosed to any other person, apart from the appointed PRMR , unless the reporting person gives his/her consent to the disclosure or in case it is required by the applicable Union or national legislation. In the latter case, the reporting person will be informed beforehand in writing, unless otherwise specified in the relevant legislation.

Persons who report violations are entitled to general protection if, at the time of the report, had reasonable grounds to believe that the information about the reported violations was true. Therefore, any kind of negative behavior towards them is prohibited (even if the report is subsequently proven to be incorrect) and the Company reserves the right to take all appropriate measures against those who use or threaten to use acts of retaliation against a person who submits a report.

In particular, the following forms of retaliation are prohibited: a) suspension, dismissal or other equivalent measures, b) demotion, omission or deprivation of promotion, c) removal of duties, change of workplace, reduction of salary, change of working hours, d) deprivation of training, e) negative performance evaluation or negative professional recommendation, f) reprimand, imposition of disciplinary or other measure, including a monetary penalty, g) coercion, intimidation, harassment or marginalization, h) discrimination or unfair treatment, i) non conversion of a temporary employment contract to a permanent one, j) non-renewal or early termination of a temporary employment contract, k) intentional damage, including damage of reputation, especially on social media, or financial damage, including business damage and loss of income, l) registration on a list of undesirables (“blacklist”), based on a sectoral formal or informal agreement, which may imply that the person will not be able to find a job in the sector in the future, m) early termination or cancellation of a contract for goods or services, n) cancellation of license or approval, o) referral for psychiatric or medical observation.

It is noted that the measures to protect the reporting persons also apply, as the case may be, to: a) mediators, b) third parties connected to the reporting persons, who may suffer retaliation in a work context, such as colleagues or relatives of the reporting persons, and c) personal businesses or legal entities of the reporting persons’ interests, or for which they work, or with which they are otherwise connected by an employment relationship.

PERSONAL DATA

Any processing of personal data related to this policy (including any sensitive data) is carried out in accordance with the provisions of the relevant national and European legislation, and the processing will be limited to the absolutely necessary data for the documentation of the report and the service of the purposes of this policy. The rights of the persons related to this data are also determined by the applicable legislation, but may be limited in the context of this policy’s implementation and for the purpose of avoiding obstacles to the investigation of the submitted report, in accordance with the provisions herein.

SUBMISSION OF EXTERNAL REPORT TO THE COMPETENT AUTHORITY

The reporting person may, in case he/she considers that his/her report was not dealt with effectively, resubmit it to the competent, in accordance with the applicable national legislation, authority, which acts as an external channel. Also, the reporting person can submit a direct external report to the competent authority according to the above.

AMENDMENT OF POLICY

This policy is subject to continuous evaluation and, if deemed necessary, will be amended in order to comply with possible changes in the relevant regulatory framework or to improve its efficiency and effectiveness. In any case, the latest updated and valid version will be posted on the official website of the Company.

UPDATE

The PRMR ensures that all employees and third party partners of the Company are informed about the content of this policy. This update is done by sending e-mail or other informative material, as well as by publishing this policy on the official website of the Company.

For clarifications regarding the report management procedure or this policy, you can contact the legal department of the Company at the following email address: legal@eurodyn.com.