1. Introduction & Commitment

Pylones Hellas S.A. has been active for more than 26 years in the field of digital technologies and cybersecurity, with integrity, transparency, and accountability as its core values.
This Anti-Bribery & Anti-Corruption Policy sets out the principles and rules that the company, its employees, and partners must follow to prevent any form of unlawful or improper advantage.
The company applies a zero-tolerance policy towards bribery and corruption.

2. Purpose

The purpose of this Policy is to:

• Protect the company’s reputation and credibility.
• Ensure compliance with Greek law, EU law, and international regulations (e.g., UK Bribery Act, US FCPA).
• Safeguard a fair and healthy business environment.
• Strengthen the trust of customers, partners, suppliers, and shareholders

3. Scope

This Policy applies to:

• All employees of Pylones Hellas, regardless of role or contract type.
• Members of the Board of Directors and Management.
• Partners, external consultants, suppliers, subcontractors, and agents acting on behalf of the company.

4. Definitions

• Bribery: Offering, providing, requesting, or accepting any benefit (monetary or non-monetary) intended to improperly influence a decision.
• Corruption: Abuse of power or position for personal gain.
• Facilitation payments: Small payments to public officials or third parties aimed at expediting procedures – strictly prohibited

5. Prohibited Practices

Strictly prohibited are:

• Giving or receiving money, gifts, hospitality, or other benefits intended to obtain favorable treatment.
• Using third parties to conduct acts of bribery.
• Any payment or “gift” to public officials, government representatives, or political parties.
• Concealing or falsifying records in accounting books to cover such actions.

6. Acceptable Practices (with limits)

The company recognizes that in certain cases, the exchange of reasonable and symbolic gifts or hospitality may help maintain professional relationships.

Permitted are:

• Low-value gifts (e.g., corporate souvenirs, branded stationery).
• Meals or coffees in the context of business meetings, provided the cost remains reasonable.
• Participation in client/supplier events, provided they are related to business activity and approved by Management.

Not permitted: regular or lavish hospitality, as it may be perceived as an attempt to influence decisions.

7. Employee Responsibilities

All employees must:

• Avoid any action that could be perceived as bribery or corruption.
• Record and declare any gifts or hospitality offered or received to the HR/Compliance Department.
• Immediately report any suspicion of violation.
• Participate in regular training programs organized by the company

8. Reporting Procedure (Whistleblowing)

Pylones Hellas has established an internal reporting mechanism:

• Employees may report incidents anonymously or by name via a dedicated email or reporting form.
• All reports will be handled confidentially.
• Any form of retaliation against employees who report violations in good faith is strictly prohibited.

9. Sanctions

Violation of this Policy may result in:

• Disciplinary measures (up to and including dismissal).
• Legal consequences (criminal or civil liabilities).
• Termination of cooperation with third parties.

10. Management Responsibilities

Management is responsible for:

• Leading by example in ethical behavior (“tone from the top”).
• Ensuring that control and record-keeping mechanisms are in place.
• Providing training and guidance to employees.

11. Monitoring & Review

This Policy is reviewed at least annually or whenever there are changes in laws/regulations.
The Compliance team, in cooperation with HR, is responsible for its implementation and continuous improvement.

Contact email for handling complaints related to bribery matters: antibribery@pylones.gr