POLICY AGAINST BRIBERY / CORRUPTION

1. Purpose

The purpose of this policy is to enact controls in order to ensure the compliance with all the applicable anti- bribery and corruption regulations and that the Company’s operations are implemented in a socially responsible manner.

2. Policy Statement

Bribery is the offer, the promise, the giving, the acceptance or the quest of an advantage as an inducement for an illegal act or a breach of trust. The bribery is an incitement or a reward, which is offered, promised or provided in order to obtain any commercial, contractual, regulatory or personal advantage.

It is our policy to conduct all our activities/business in an honest and ethical manner. We adopt a zero tolerance approach to bribery and corruption. We are committed to act professionally, fairly and with integrity in our business dealings and relationships whenever we operate and by implementing and enforcing effective anti-bribery systems.

We will comply with all the laws, which are related to anti-bribery and anti-corruption, in all jurisdictions in which we operate. However, we remain bound by the Greek laws, regarding our conduct both at the inside and abroad.

Bribery and corruption are punishable by imprisonment and fines. If we are found to have participated in corruption, we could face an unlimited fine, be excluded from tenders for public contracts and have our reputation damaged. Therefore, we take our legal responsibilities very seriously.

We are committed to comply with all the requirements of ELOT EN ISO 37001:2017 and to the continuous improvement of the Anti-Corruption Management System.

In case of a complaint you can contact Mr. Nikolaos Dimopoulos (tel. 2109245398, e-mail n.dimopoulos@atese.gr) and for an anonymous complaint you can send an anonymous letter to the company

President of the Board

Panagiotis Choumpavlis

HLD_ABP V. 1.0, 04/07/2024