The Top Management of the Organization is committed to establishing, implementing, maintaining and continually improving the Anti-Bribery Management System that it applies in accordance with the international standard ISO 37001:2016.
The Top Management of the Organization is committed to high standards of ethical conduct and requires all employees, business associates and other interested parties with which it cooperates to comply with this policy without exception.
All employees, including Management, have been trained in relation to this policy.
Medisports Ltd applies a zero-tolerance policy against bribery, corruption, facilitation payments or any other unlawful act, and follows the procedures provided by law for the disciplinary prosecution and punishment of personnel who violate this Policy.
Medisports Ltd only permits the receipt and offering of official customary gifts (up to 50 euros) in accordance with the provisions of the Greek State, where this is reasonable and proportionate to a relationship. Gifts are avoided if there is a risk that they may be perceived as influencing decision-making.
Medisports Ltd will not cooperate with businesses involved in corrupt practices and will immediately terminate any relationship with associates or other interested parties should such cases arise. The Management and employees of the Organization comply with the national and European Union laws on bribery that apply to it.
Where legal and other relationships in certain countries may deviate from this Policy, Top Management will decide on the due diligence arrangements to be carried out before entering into any relationship or cooperation. However, without exception, the Organization does not participate in offering or accepting bribes.
Medisports Ltd will not knowingly participate in any transaction where corrupt practices form part of the agreement. When associates or other interested parties represent Medisports Ltd, they must, within the framework of their contractual obligations, agree to follow this policy.
All their fees and expenses must be lawful, reasonable, justified and supported by evidence.
Conflicts of interest are not acceptable. It is a condition of employment that Management and employees do not conduct private business, political or charitable activities within the scope of the Organization that involve a conflict of interest.
Such activities require the prior written permission of Top Management, which is granted provided that there is no conflict of interest. It is a contractual requirement that all contractors and other interested parties declare to the Organization, before representing it in any way, whether they have any actual or potential conflict of interest with a specific interested party. The Organization does not participate in any political or party donations.
In the case of a charitable donation, the written consent of Top Management is required. Management, staff and contractors use confidential reporting channels to raise concerns and complaints.
Furthermore, all members of Management are informed of how to handle concerns reported to them, and failure to report and investigate such concerns constitutes a serious disciplinary and possibly criminal matter. Under no circumstances will there be any form of retaliation as a result of using the reporting channel.
If any conduct is observed that may violate this Anti-Bribery Policy, or if any member of Medisports Ltd staff is approached for purposes of bribery or corruption, we urge anyone to immediately contact the Anti-Bribery Management System Officer by calling 2112146303 or by sending a message to [email protected]. Medisports Ltd will handle the report confidentially, to the extent permitted by Law. If the reporting person so wishes, reports may be submitted anonymously.
The Anti-Bribery Management System in accordance with ISO 37001:2016 has been implemented to prevent Medisports Ltd from participating in any corrupt process, and to handle and report cases where further investigation and action may be needed. It is fully supported by senior management.
The Board of Directors is regularly informed of all matters relating to the Anti-Bribery Management System, and the Policy and the Procedures supporting the System are reviewed at least annually. Top Management is committed to and supports the implementation of the Anti-Bribery Management System in accordance with this Policy and the defined objectives, in order to adequately mitigate the risk of bribery for the Organization.
The Bribery Compliance and Investigation Committee is responsible for answering any questions and clarifying any bribery-related issues concerning staff.
The Bribery Compliance and Investigation Committee promotes the resolution of any issues arising from these communications. This policy is communicated internally and externally, ensuring that associates, interested parties and employees are informed of the Organization’s commitment to combating bribery.
ATHENS 5/11/2024
MANAGING DIRECTOR:
THEODOROS DIAMANTIS
