CODE OF CONDUCT

Introduction

Our company has been operating since 1977. Its form and operating structure has changed over the years, and is constantly enriched with new activities. In all these years however, my family’s values have remained stable with respect to the company’s sustainable growth; always guided for the better service of our customers as well as creating a working environment governed by honest and humane relationships between us.

It is my family’s common belief for the dissemination of stable values to all involved parties and primarily that these values to be constantly reflected through the relationships and contacts of the company’s workforce with all involved customers, suppliers and government officials. This is why I have undertaken the initiative to establish and record the values that I want all of us to believe in, in this Code of Ethics.

I believe that the following text depicts everything my family has been doing all these years, through its business activity and it is important that each of you reads, understands and fully complies with our Code of Ethics. It is your responsibility to defend the adherence to the Code but also to report any situation which you reasonably believe is contrary to our Code of Ethics.

The reputation of MOBIAK SA lies in the hands of each of us. I thank you in advance for your constant dedication to our common values and your ethical leadership, which is crucial to the continuation of our business success.

Svourakis Emmanouel

President & Managing Director

Owner MOBIAK SA


MOBIAK SA has established this Code of Ethics aiming at the Code guiding our daily business interactions, reflecting our standard for our correct conduct and our corporate values. We believe that our business activities are supported on directness, responsibility and compliance. The way in which we achieve our business results is equally important to their achievement. The Code of Ethics of MOBIAK SA applies to all the people of MOBIAK SA; including the Supervisors, Executives and all Company employees as well as its subsidiaries around the world. Our partners and suppliers are subject to these requirements, since the adherence to the Code is a requirement for the continuation of their collaboration with us.

The MOBIAK SA Code of Ethics is structured to reflect the expectations of our stakeholders. The stakeholders are individuals with a constant interest in our company. They are the customers, the suppliers and the markets – the customers who are satisfied and feel that we understand them, the suppliers who appreciate that we are demanding but also fair, and the markets, in which we play an important role. The shareholders – who expect our organization to maximize the value of their investment. The employees – who work with enthusiasm and pride since they feel challenged but also appreciated. The communities – in which our role is practical and positive.

Our management is determined to ensure that we are the best in our category with respect to compliance in all the markets in which we operate. Each employee is responsible to demonstrate integrity and leadership with his / her compliance to the provisions of the Code of Ethics, the Company policies and all applicable laws.

 

Are the standards for managers higher?

Individuals who hold the position of manager or supervisor, depending on their position at the company and their respective responsibilities, are expected:

– To support and to promote a work environment where ethical conduct is recognized, appreciated and is an example to be imitated.

– To ensure that their subordinates and their teams understand and follow the code and have the resources to do this.

– To support the employees who in good faith pose questions on issues of ethics.

– To monitor and consistently impose the standards defined in the code.

– To give a good example and to encourage others to do the same.

This Code does not replace your responsibility for using correct judgment and using common sense; we are demonstrating our commitment for a culture that promotes the highest possible standards of ethics.

Introduction

Before you take any specific action, you should yourself:

 

  • Am I authorized to do this?
  • Is this action the correct thing to do?
  • Is this action lawful and consistent with the Code of Ethics or with other policies?
  • Would I be proud if I mentioned this action to someone that I respect?
  • Will this action further improve the reputation of MOBIAK SA as an ethical Company?

 

If the answer to any of these questions is NO, or if you have any questions on the interpretation or the application of the Code of Ethics or any standard, policy or procedure of MOBIAK SA, you must discuss this situation with your Supervisor, the Human Resources (HR) Department or Management representative (President of MOBIAK SA).

No negative action will be taken against any person who submits complaints / reports, who participates or assists in the investigation of a possible violation of the Code of Ethics, unless that claim has been made based on information that is intentionally false. MOBIAK SA will preserve the confidentiality of all reports to the maximum extent possible. The Code is available online and has been translated into English.

Workplace - Work Relations

All of your transactions with your colleagues, your subordinates and your supervisors must be carried out in a climate of cooperation, where each person’s behavior is governed by a basic commitment to ethical conduct and the success of MOBIAK SA. Your relations which those with which you cooperate must be like a member of a team that is winning. People who cooperate harmoniously and focused on common goals are the guiding force behind our success. For that strong group relationship to work, each person must respond to his / her responsibilities – and feel certain that everyone else will do the same. This means providing the necessary support to others, at all levels, to carry out any kind of work. No individual or business unit should place their own priorities above those of the Company.  Your relationships with your colleagues or subordinates must promote ethics and compliance and be an example of honesty, impartiality and integrity in cooperating with others. As a leader, you are responsible for clearly defining performance standards and creating an environment that promotes team work.

Communication

You should encourage the creative and innovative way of thought and if you are a supervisor, you should treat your subordinates as independent persons, giving them the necessary freedom to complete their work. Provide suggestions for improving performance. Your relationship with your supervisor must be based on mutual respect and trust. You and your supervisor are a team with the common purpose of achieving the goals which have been established by the Company for your unit. You are equally responsible with your supervisor to ensure open and honest communication between you. You should undertake initiatives as frequently as possible. Use innovative ways to solve problems. Your cooperation and creativity are important factors in achieving the goals of your unit and of the Company.

Employees

In issues of employment, it is our policy to:

  • Select, appoint and compensate all employees of MOBIAK SA based on their qualifications for the work that must be completed and without discrimination due to matter, religion, national origin, nationality, color, race, sex, age, sexual preference, marital status, disability or any other characteristics protected by the law.
  • Not use children for our work. Child labor is defined as the employment of any individual who is under the minimum age permitted by law in the respective area of jurisdiction; however, in no event will we hire knowingly an individual who is under the age of sixteen (16) years old.
  • Provide a workplace that welcomes diversity and achieves superiority by attracting and keeping people from all backgrounds in our workforce.
  • Provide opportunities for education, training and distinction / promotion that allow the development and promotion of the career for all people of MOBIAK SA.
  • We conduct performance evaluations that provide honest and accurate feedback.
  • We encourage two-way comments and discussions as well as review of the evaluations by the highest levels of management.
  • We compensate performance and recognize and reward contribution by individuals and teams that exceed their standard work duties.
  • We prohibit the sexual or other kind of harassment of the people of MOBIAK SA by anyone else in the workplace, or during the conduct of operations of MOBIAK SA.
  • We avoid discriminatory behavior or even its suspicion in the workplace, in accordance with the policies and procedures adapted by the Company.
  • We respect the privacy of individuals and we collect, process, use and maintain the personal information of employees only to the degree necessary and in accordance with the laws of the countries in which we operate.
  • We make efforts to eliminate potential risks from the workplace and to provide a safe and healthy environment for the people of MOBIAK SA, and to make efforts for the compliance to all applicable laws and standards of occupational health and safety.
  • We help in keeping a safe, healthy and productive workplace for all the people of MOBIAK SA and others, prohibiting:

– the possession, use, sale or transport of illegal substances/narcotics or tools for use of drugs in the facilities of the Company or during the working hours for the Company

– the conduct of work of the Company under the influence of alcohol

– the possession or use of weapons or ammunition in the facilities of the Company or during the conduct of work of the Company based on local legislation. Possession of a weapon may be authorized by the security personnel when this possession is considered necessary for ensuring the safety and protection of Company employees and

– the immediate reporting to management of any incident of use or possession

– of illegal substances / narcotics, alcoholic beverages or weapons.

Conflict of Interest

Your judgment is one of the most valuable things you have. You must avoid any activity or association that comes into conflict with the exercise of your independent judgment or appears to come into conflict with it; in the best interest of the Company. Conflicts of interest may arise in many situations. It is impossible to cover all of these in the present document and it will not always be easy to distinguish between suitable and unsuitable activity. When in doubt, consult your supervisor or the Managing Director of your unit before taking any action.

The following guidelines apply to most situations of conflict of interest.

Investments

Do not proceed to any investments that may affect your business decisions. Company policy prohibits the people of MOBIAK SA to hold shares or proprietary interests in any company which is a competitor or partner of MOBIAK SA. This prohibition does not apply to the possession of small amounts (generally under 1%) of shares of a listed company, provided that the investment is not very significant economically so as to create the suspicion of conflict of interest. If you had made potentially prohibited investments prior to your cooperation with MOBIAK SA, report these events to the Managing Director.

 

Family

Notify your supervisor and receive approval from your Department or the supervisor of your work duties and the Managing Director before conducting business on behalf of MOBIAK SA with any company in which you, or a member of your close family environment, may have proprietary interest such that you can benefit from any means through your own actions or the actions of a member of your family.

 

Other work

Do not work for a competitor when employed by MOBIAK SA or do not perform any work or provide assistance to any third party, where such work or assistance could affect your performance or judgment in your employment within MOBIAK SA. Do not use the company name, the facilities or materials of the Company for outside work not related to your employment at MOBIAK SA without receiving authorization from your Department or your supervisor.

 

Personal issues

Even though we acknowledge and respect the rights of the people of MOBIAK SA for the free association with people encountered in their work environment, we must however use our judgment to ensure that these relationships do not affect negatively the work performance, the ability to supervise others, or the actual work environment.

Any behavior in the workplace resulting from a ‘romantic’ relationship or friendship between employees could be inappropriate if this behavior creates a hostile or unfriendly work environment for others. Any favoritism or the taking of business decisions based on feelings, alliances or any friendship contrary to the interests of the Company, is prohibited. Individuals who maintain personal relationships or friendships must use discretion, good judgment and sensitivity. You must have perception of the fact that a certain member from your own family environment could be recruited in a position that could create or suggest a conflict of interest. If such a situation should arise, you must consult your supervisor or the Managing Director of the company for guidance.

Boards

You must obtain approval from the President / Managing Director, prior to agreeing to serving on any Board of Directors or similar body for an outside business or government office. Serving on a Board of Directors for a professional or work-related non profit organization must be approved in advance by your Supervisor

Proprietary Information of the Company

The trade secrets of MOBIAK SA, other proprietary information and the greater part of its internal data are valuable assets. Protecting these assets, including their secrecy, plays a vital role in our continued growth and our competitive ability. Trade secrets are information used in relation to the operations of MOBIAK SA which are not generally known or cannot be discovered easily and for which efforts have been made to keep secret. However, other proprietary information such as technical know-how, must also be protected.

The trade secrets of MOBIAK SA and other proprietary information may consist of any type, design, device or information used in our company and which gives to MOBIAK SA the opportunity to acquire a competitive advantage. Trade secrets and other proprietary information of MOBIAK SA are not always technical in nature. They may also include business research, designs for new products, strategic goals, any non published financial information or information regarding pricing, lists of employees, customers and suppliers, as well as information related to requirements, preferences, business habits and customer plans. Even if not exhaustive, this list demonstrates the wide range of information which must be protected. The trade secrets and other proprietary information do not have to be covered by patents, but should not be made generally known or disclosed to the greater public.

Your obligations related to the trade secrets and other proprietary information of MOBIAK SA include:

  • The non disclosure of information to other persons of MOBIAK SA except in cases of “need to know” or “necessity of their use”.
  • The non disclosure of this information to persons outside of MOBIAK SA.
  • The non use of this information for own benefit, or the benefit of persons outside of MOBIAK SA.

If you resign or are dismissed from MOBIAK SA, your obligation to protect the trade secrets of MOBIAK SA and other proprietary information continues to apply until the information is made publicly known or until MOBIAK SA no longer considers this information as trade secrets or proprietary.

The above are also described in the employment agreement which is signed, acknowledged, applicable and adhered to by the Managing Director and each employee.

You must also remember that any correspondence, printed material, electronic information, documents or forms of any nature, knowledge of specific procedures, processes and special ways in which MOBIAK SA conducts its business – confidential or not – are property of the Company and must be kept at MOBIAK SA.

Of course, the personal skills acquired or improved through work, are personal information of the person who resigns or is dismissed. If you have any questions on which information are proprietary or are trade secrets, you must contact the Managing Director.

Maintenance of Reliable Records and Reports

The financial position of the Company and the results of its operations must be recorded in accordance with the requirements of the law and the generally accepted accounting principles (GAAP). Company policy, as well as the law, requires that MOBIAK SA keep books, records and accounts that accurately reflect and without bias the nature of the business transactions and the disposal of the assets of the Company. The integrity of the accounting and financial records of the Company is based on the accuracy and completeness of the basic entries supporting the information in the account books of the Company.

All those participating in the development, processing and recording of this information are considered responsible for their integrity. Any accounting or financial entry must reflect precisely the data described in the supportive information. There should be no withholding of information from management, or the internal or independent auditors of the Company.

No payment on behalf of the Company shall be approved or made with the intent or understanding that any party to such payment could be used for any purpose other than that described by the documents supporting the payment. There shall be no entries of false or misleading entries in any books or Company records for any reason and prohibited is the establishment, acquisition, or retention of any capital, asset or account of the Company for any purpose unless such capital, asset or account of MOBIAK SA is reflected appropriately in the books and records of the Company. No funds or assets shall be used for any illegal or inappropriate purpose. The managers and other executives, responsible for the preparation of financial information must ensure that all corporate financial policies of MOBIAK SA are adhered to.

The entries of income and expenses must be recorded in a timely manner. The assets and liabilities must be recorded and evaluated appropriately. Moreover, those responsible or involved in the procedure of submitting documents to the Securities Commission and Stock Exchanges of Greece and other submissions of documents required by applicable legislation, or other transactions with the business or financial community, must ensure that said submission of documents and transactions contain disclosures that are complete, fair, accurate, timely and understandable. In the event where you find any omission, falsification or inaccuracy in the accounting or financial entries, to basic data supporting said entries, or in the reports of MOBIAK SA to the Securities Commission and Stock Exchanges of Greece or other means of communication, or any malfunction of the internal audits, you must immediately report this information to your supervisor or the Managing Director of the company.

Assets of MOBIAK SA

The assets, facilities or services of the Company must be used only for legitimate, suitable and authorized purposes. The theft of money, assets or services is strictly forbidden. The equipment, systems, facilities, company credit cards and consumables of MOBIAK SA must be used only for the conduct of MOBIAK SA business or for purposes authorized by management. You are personall y responsible not only to protect the assets of MOBIAK SA for which you are responsible, but also for the general protection of all Company assets. You must be vigilant of any situations or incidents which could lead to the loss, inappropriate use or theft of assets of the Company and must immediately report these situations to your supervisor or to the Head of Security. Only specific executives appointed by Management are authorized to proceed to commitments that affect the assets of the Company. You must not make commitments that affect the assets of the Company unless you are appropriately authorized. If you need to clarify your authority or the authority of anyone else on the commitment of the Company, you must contact the head of finance of the company.

Information Technology Resources

We must use the Information Technology Resources of MOBIAK SA with responsibility and in a manner consistent to the Code and all other Company Guidelines, including those related to specific computer technologies, data protection, confidential and proprietary information and intellectual property rights. The Information Technology Resources of MOBIAK SA include any computer equipment owned, leased or rented by MOBIAK SA, regardless of the location where it is found, including, without limitation, the personal computers, laptops and their devices, network servers and access devices to the Internet, the MOBIAK SA internal network and the electronic mail network (email). This also includes voice mail and other voice systems, facsimile machines, telephones, digital assistants, instant messaging and information acquired or received from or transmitted through the Internet and the MOBIAK SA internal network. The “Information Technology Resources” also include access to the network and the electronic mail (email) system of MOBIAK SA from a computer that is not owned, leased or rented by MOBIAK SA (e.g. home computers).

All Information Technology Resources of MOBIAK SA are assets of MOBIAK SA and include all information created, stored, or transmitted with the use of the Information Technology Resources of MOBIAK SA. The only information not considered assets of the Company is the information received during the limited personal use of the Information Technology Resources of MOBIAK SA, or information that does not appear to comprise assets of the Company in accordance with the applicable laws and regulations.

The Information Technology Resources of MOBIAK SA must be used for the business purposes of MOBIAK SA.

 

The following is prohibited:

  • Harassing, discriminatory, slanderous or threatening messages, including messages with content that is offensive to any race, sex, age, sexual preference, religion, political convictions, nationality, state of disability, state of veteran, sexual identity or other characteristics protected by applicable legislation.
  • The dispatch, access or storage of any type of offensive or obscene messages or materials.
  • The communication between employees as well as with persons outside the company through electronic computers and during work hours on matters not related to the work carried out.
  • Unauthorized distribution of proprietary, confidential or trade secrets of MOBIAK SA.
  • Causing or providing license for violations in security or communication network interruptions, and / or inappropriate disclosure of your access code to others, or license to use your access code by others.
  • Violations of the rights of any individual or company, which are protected by copyright, or by the law on trade secrets, patents, or other intellectual property rights, or by similar laws or regulations.
  • Violations of privacy rights of any individual protected by applicable law.
  • The pursuit of collaboration with any outside organization, business or purpose not related to MOBIAK SA, including for instance, any trade, religious, or political organizations, businesses or purposes. Except for the cases permitted by applicable law, MOBIAK SA reserves the right to monitor the equipment, systems and network activities, including, without limitation, the use of electronic mail, voice mail and Internet, as well as any stored information, in appropriate cases and in accordance with applicable law. Moreover, for the requirements of functions related to maintenance, security, operations, as well as legal or regulatory requirements, authorized personnel and third services providers may have unlimited access to information in the Information Technology Resources of MOBIAK SA, to the full extent permitted by law.

MOBIAK SA retains the right to terminate the access of any user to the Information Technology Resources of MOBIAK SA, at any time, with or without prior communication.

Direct and Open Communication with Management

Company employees should be able and have, daily and direct communication with senior management. When decisions must be made, in case where there is reason for information, a member of senior management is present and available to provide valuable advice. Meetings as well as dialogue between employees and senior management take place in person as well as through the use of technology (e-mail, telephone etc). This position of the Board of Directors enables it to play an active role in the development and guidance of the Company’s business strategy. The office of the President and Managing Director of the company is centrally located within the facilities and is next to the departments of Imports, Exports, Quality Assurance and Public Relations.

Suppliers and Customers

Our goal during the conduct of our purchases is to secure uninterrupted and reliable sources of supplies. Honest dealings with customers and suppliers is of the utmost importance for stable and long term relations. Thus, we view our suppliers as our partners and we expect them to have reasonable profits from these dealings. We provide to all our prospective suppliers unbiased and equal opportunities. Decisions are based on objective criteria such as price and quality, as well as the reliability and integrity of a supplier. Prohibited is the provision, credit or receipt of any illegal commissions (“kickbacks”), bribery or similar payments of any type. We do not make personal favors to customers with respect to prices, advertising offers, product marketing assistance, or related. We place all our customers on the same business ethics basis. Dealings with customers and suppliers are discussed in the section of this Code that determines our responsibilities in accordance with the laws on competition.

The Code of Ethics of MOBIAK SA is communicated to suppliers and partners. They are informed of the Code of Ethics that governs MOBIAK SA and their cooperation with us must comply accordingly. The Code of Ethics is also available on our website www.mobiak.gr.

We do not Give or Accept Inappropriate Gifts

It is not acceptable to give or to receive gifts, payments or other benefits in order to influence any type of business decision. If you intend to give or to receive a gift, payment or other benefit with a value more than negligible, then you must communicate with the Managing Director for prior approval. You should also know that you may accept only one gift of negligible value from one source, only once per calendar year. In the event the Company may find itself in a difficult position if you do not accept a specific gift whose value may be more than negligible, then the acceptance of the gift by you must be reported to the Managing Director. The Managing Director will assist you in determining the appropriate attitude. Also, do not make arrangements for providing or accepting any gift, payment or other benefit with value more than negligible on behalf of a member of your family, from anyone with which the Company has a business relationship or from anyone who wants to establish a business relationship.

Follow this rule: Do not accept any gift or service obliging you to make settlements, or if this may suggest settlement on your part. This does not include cases of business lunches or dinners, which you may reciprocate in the same manner, or gifts of negligible value.

There are special rules governing appropriate ethical conduct in your transactions with federal, state, local or foreign government authorities which differ from the rules of transactions with non government companies. In general, you are forbidden to offer to government officials any gift, tip or any object of value, including meals or trips, unless you have received prior approval from the Managing Director.

We Respect the Trade Secrets and Confidential Information of Others

It is a policy of MOBIAK SA to not knowingly violate the intellectual property rights of others. It is also company policy to respect the trade secrets or other proprietary information of third parties. This is especially important if you have knowledge of trade secrets and proprietary information from previous employers. If you have questions on this matter, consult the Managing Director.

If anyone outside the Company approaches you on an invention, discovery or idea, it is important to protect the Company from any future violation or monetary claims, especially in cases where our own efforts or the efforts of our consultants resulted in the same invention, discovery or idea, which we wish to apply to a product of the Company. Do not allow outside third parties to reveal any details of their inventions, discoveries or new ideas.

We Establish the Highest Possible Standards for our Products

We have undertaken the commitment to ensure that consumers can trust the products of MOBIAK SA with respect to their reliability, quality and exceptional performance. In addition to serving our large customer base in the markets where we do business, we must make every possible effort to produce our products in the most effective manner, so they are purchased by as many consumers as possible.

The products sold by MOBIAK SA must not only meet all the safety standards specified by law, but also our own, frequently more strict, Company standards.

We participate in programs to provide immediate assistance to consumers in case of inappropriate handling or use of our products. The health, safety and welfare of consumers is a matter of utmost importance to us and you, as an employee of MOBIAK SA, are responsible to immediately report any issue related to quality or safety to the supervisor of your business unit.

We Respond to Consumers

Even though our company does not deal directly with the retail sector, however it remains open to comments and questions from users of our products. These comments may be expressed either directly from consumers to us (e.g. through any communication form we have available, telephone, e-mail, website etc.) as well as through the network of the group’s subsidiaries and its partners in Greece and around the world.

When a consumer expresses dissatisfaction, we immediately deal with the issue in a polite and unbiased manner and make all reasonable efforts to maintain or restore the consumer’s good faith and the continued purchase of the MOBIAK SA products.

Advertising

Advertising must be creative and competitive, but simultaneously honest and accurate, not misleading and in compliance with applicable legislation. Advertising must avoid any stereotype of individuals based on factors such as race, religion, nationality, color, sex, sexual identity, age, citizenship, sexual preference, state of veteran, marital status or other state of disability, or any other characteristics protected by law.

Advertising creates more than an image about the product. It builds our reputation with certainty, reliability and solvency. Further, we are particularly careful when choosing the media in which our advertising messages will be shown. We do not allow our advertisements to be shown on television programs or other media which make use of violent content, or sexual content, or are anti-social or negatively affect the reputation of our products or our Company. We maintain standards of commercial impartiality during the preparation, use and selection of advertisements, trademarks and designs, so that our products succeed based on their actual quality and reputation, and not based on imitation or exploiting the good faith of competitors.

 

Commercial impartiality requires:

 

  • Strict compliance to local legal requirements on trademark falsification and unfair competition.
  • The avoidance of copying widely known trademarks, slogans, advertising material and graphics used by multinational companies and regional competitors outside your area.

We Comply with the Law on Competition

It is the policy of MOBIAK SA to fully comply with all laws on competition of each country and location where it conducts its business. The purpose of the laws on competition is to protect the competition procedure to the benefit of consumers. Competition laws ensure that companies compete to win business offering lower prices, innovative products and better services and that they do not interfere with the supply and demand of the market. The laws on competition also protect companies from “predatory” or unfair practices from dominant companies, so that the field of competition is open and fair for everyone.

MOBIAK SA supports the goals of the laws on competition. We believe that the Company performs better in a competitive market environment. Almost every country has established competition laws. It is your responsibility to monitor and understand the laws in the countries under your supervision and to seek guidance from the Managing Director for any question you may have after presenting all possibilities for handling the case that is of concern.

You must adhere to the letter and the spirit of the applicable laws. Competition laws around the world prohibit agreements between current or potential competitors which harm competition. The key to compliance is independence. MOBIAK SA must act independently in its business operations – in establishing prices, discounts, promotions and purchase and sale terms, in selecting customers, distributors and suppliers and in selecting products to promote and how these products are sold. It is important to remember that any illegal agreement does not have to be officially in writing, or even simply in writing. It can be an oral agreement or implied by various aspects of business conduct or comments in documents. Further, an agreement does not have to be successfully applied in order to be illegal.

The laws on competition also impose specific boundaries in the relationships between customers and distributors. In most countries, any attempt to deprive freedom of setting prices and the sales terms and conditions by customers or distributors, or establishing unjustified limitations in their right to act independently, is a violation of competition laws.

The consequences for non compliance to the competition laws are very serious for MOBIAK SA and its people. The violation of certain laws on competition can lead to monetary fines, even imprisonment for individuals involved and even greater fines for the Company. Further, even without criminal prosecution, civil actions may be raised for compensation and legal expenses.

If you have any doubts on whether an attempted action could raise issues for violation of competition laws you must consult the Managing Director of the Company.

We Comply with the Laws on Securities

In certain cases you may have information related to MOBIAK SA or other companies, listed in the stock exchange with which MOBIAK SA conducts business or negotiates “insider” information – namely information not known to the public – such as non-published (temporarily) profit data, potential acquisition or sale of subsidiaries, marketing plans or new product presentations.

The information is considered non-public until adequately disclosed to the public, i.e. when the information is publicly disclosed and enough time has gone by so the Securities markets have fully absorbed said information.

 

If this non-public information is “material”- namely information taken into account by a prudent investor when making investment decisions – then, in accordance with applicable laws on Securities (transferable securities) and the policy of the Company:

  • You must not purchase or sell on your own behalf or on behalf of any third party any shares, bonds or other securities of the company (MOBIAK SA or other) relating to this non-public information.
  • You must not encourage or urge others, based on this non-public information, to purchase or sell shares, bonds or other securities of these companies.
  • You must not disclose this non-public information to persons outside of MOBIAK SA.
  • You must not discuss without reason this non-public information with persons within MOBIAK SA.

Employees or partners of MOBIAK SA who have knowledge of non-public information related to MOBIAK SA must especially take care to maintain their confidentiality and must not purchase or sell shares, bonds or other securities of MOBIAK SA, or shares, bonds or other securities of any other involved company, prior to the disclosure to the public of this non-public information and for a reasonable period of time after this disclosure.

This prohibition also extends to exercising option rights of shares. If you resign from MOBIAK SA, your obligation to maintain the confidentiality of said non-public information continues until said information has been adequately disclosed to the public.

If you have any questions related to whether said non-public information has been disclosed to the public, you must contact the Managing Director and refrain from any purchase or sale of affected Securities or any disclosure whatsoever of the information until you have been informed that the information is not material or has been disclosed and made public knowledge.

We do not make Political (Party) Contributions

The use of funds or assets of the Company for contributions to any political party or candidate, on a national or local level or abroad, is forbidden. Political contributions include direct contributions (namely monies) and contributions in kind. Contributions in kind include the purchase of vouchers (tickets) for sourcing funds, contribution to products, voluntary work by the people of MOBIAK SA during work hours and the use of the facilities of MOBIAK SA for purposes related to sourcing funds or for political purposes. If you have any questions with respect to contributions in kind, please consult the Managing Director.

It is prohibited for the Company to compensate or reimburse money to any person of MOBIAK SA or individual related to the Company (including outside political intermediaries), directly or indirectly, in any form, for political contributions it intends to make or has made to said person. Independent individuals of MOBIAK SA are free to make personal contributions to candidates or parties of their choice. Personal contributions are the responsibility and burden of the independent person making such contributions. MOBIAK SA shall not accept any liability or obligation with respect to any personal contribution. Further, any personal contribution made with the intent to assist MOBIAK SA or one of its partner companies for winning or retaining business, is not permitted.

The participation in parties as a candidate on local and / or national level is forbidden without the approval from the Board of Directors of the company.

We Trade Ethically with the Government Sector

We must not pursue to influence the judgment of any government employee, or promise gifts or other benefits, or any other illegal incentive. Therefore, it is important to not offer any gifts, entertainment or other objects of value to government employees, unless you have received permission from the Managing Director.

Further, certain laws on lobbying may require from the Company or its employees to register and be referred to as lobbying factors if an individual of MOBIAK SA contacts a government employee with the purpose of influencing legislation or specific other official actions. If you are involved in any such activity, you must inform the Managing Director.

The commitment of MOBIAK SA for lawful and ethical dealings with government sectors, applies to the whole world. The policy of the Company and the laws on bribery around the world prohibit our employees or their representatives to provide or to offer to provide money or any object of value – whether in cash or not, directly or indirectly through third parties – to any foreign official (i.e. employee of foreign government, political party of foreign country, or party official or foreign political party candidate) with the intent of urging said official to influence any action or decision of the government, or to assist the Company in winning or retaining business.

To ensure that you do not violate this standard, it is a policy of the Company that, aside from the lawfully imposed duties (for instance required license duties), payments must not be made or gifts related to the business activities of the Company to any foreign country official, directly or indirectly, unless approved in advance by the Managing Director as a lawful action in accordance with the laws of Greece and other applicable laws.

Always be honest and sincere in your dealings and communication with government employees.

Any false statements made intentionally or knowingly to government employees (oral or written) and in particular, any false statement made under oath, may expose the Company and its people to significant penalties.

We Keep Records in Accordance with the Law

We comply with all laws and regulations related to maintaining the records of the Company (including printed documents and electronic data). The Quality Assurance Manual of the Company determines the procedures and work instructions of the Company relevant to the maintenance of files, which all departments of the Company must keep. The finance department is excluded from these reports in the Quality Manual since it is outside its scope. The audits and the monitoring of the accounting department’s operation is made based on the application of specific laws of the state on the operation of accounting departments of companies.

Contact the person responsible for the Management of the Quality System, the Managing Director or the Chief Executive Officer for more information on instructions for maintaining documents that apply to the department in which you belong.

If you are aware or have already received a report for judicial summons, judicial procedure or oncoming government investigation, immediately contact the Managing Director of the Company. In that event, you must preserve all files and records that could relate to the case of the judicial summons, judicial procedure or the investigation, regardless of the requirements of the Records Retention Program. You must not destroy or alter these records, since the inappropriate destruction could have serious consequences – including civil and / or criminal penalties – for the Company and for you personally.

If you have any questions related to whether a file or record is related to any investigation, judicial procedure or judicial summons, contact the Managing Director prior to rejecting said file.

We Comply with the International Trade Regulations

While conducting domestic business and foreign business, the Company fully complies with all applicable laws – in particular with the laws of the EU – which govern imports, exports and the conduct of business with entities outside the Member-States of the EU.

These laws contain restrictions on the types of products permitted to be imported into the European Union, as well as how they are imported. Further, they prohibit exports and many other dealings with certain countries, as well as cooperation or participation in foreign country boycotts, for which boycotts from the EU do not apply.

The people of MOBIAK SA must conduct the business of the Company so as to fully comply with the laws of the countries in which they operate. However, there may be cases of conflict between the laws of one country and the respective laws of the EU or the policy of the Company. If you become aware of such legal conflict, you must inform your supervisor and consult the Managing Director.

We Participate in Local Efforts of Contribution and Volunteerism

Our company believes in applying Corporate Social Responsibility and within each year tries to participate in one or more activities. These include help to charity organizations by offering money or other useful material, conducting and developing educational programs to students of the local community related to our activities as well as the environment, or donating its products for the material support of services and organizations of the state. It participates as sponsor in local Athletic organizations, consistently and actively, promoting the spirit of athleticism to the local community and within the company. Further, it encourages its personnel to participate in local charity activities of their choice, in their free time.

We Cooperate with Government Authorities in Matters that Affect our Company

The Company has subsidiaries, branches and representatives in more than 72 countries. These countries include France, Switzerland, Belgium, Bulgaria and other European countries as well as countries of the Middle East (Qatar, Saudi Arabia etc) and countries of Africa.

Also, it has an exports and Quality Control company in China. It is our policy to work in a cooperative spirit with the local and national governments. At times, issues may arise that affect our businesses. After careful consideration, the Company shall offer recommendations and viewpoints to state authorities on specific issues, aiming at supporting our business goals and needs.

We are Against Inhumane Work Practices of Exploitation

MOBIAK SA is opposed to the illegal use of child labor, the exploitation of children and any other form of unacceptable treatment of employees. Further, it is the policy of MOBIAK SA to not cooperate with any supplier or contractor known to operate with unacceptable practices relating to the treatment of employees, such as the exploitation of children, corporal punishment, poor treatment of women, non voluntary employment, or other forms of poor treatment. The Company does not accept any form of the poor treatment of children or violation of labor law whatsoever and if the Company becomes aware of any violation of our principles, it shall be cause for the immediate termination of the business relationship.

We Actively Participate in Local or National Crises

Due to its operations, MOBIAK SA is a strategic player of the local community and the country in cases of crisis management. Thus, in cases of extensive destruction or fire in the community in which it belongs, we are part of the civil protection plans of the state and have the obligation to immediately provide materials and equipment to protect society as a whole.

Further, in cases of national need and / or war part of our personnel is mobilized to serve the country by operating our plant.

We are Dedicated to Sustainable Development

At MOBIAK SA, sustainable development is a mandatory long term business practice, and critical to the Company’s success.

Moreover, we are determined to achieve the goal of global sustainable development to ensure that MOBIAK SA grows consistently and responsibly and benefits all those we serve, including the employees and other partners around the world, simultaneously promoting the prosperity of future generations.

We Conserve and Protect the Environment

The Company is certified under the Environmental Management System ISO 14001:2004 on the application of procedures aiming at protecting and minimizing impacts from its operation to the natural environment. As a company we have established our Environmental Policy which is reviewed annually, approved by the Managing Director and is available to all personnel and partners. It is the desire of Management that we all comply strictly to the letter and spirit of the applicable laws and regulations on the environment and the public practices they represent. No person or executive of the Company shall have the authority to be involved in conduct that does not comply with this policy, or to authorize, direct, approve or praise such conduct by any other person.

We shall promote open communication with the public and seek an active and productive cooperation with the communities in which we operate. We will continue to share information with consumers on our policy and programs concerning the environment and cooperate with all community leaders and any one else who shares our commitment to protect the environment for future generations.

In our constantly changing world, MOBIAK SA places priority in the operation of our company in a responsible and respectable manner. These efforts have lead to increased effectiveness and economic benefits for the Company. We know they are still many more things to be achieved. Our consistent strategy to reduce the impact to the environment will remain an integral part of the production, packaging, distribution and marketing of our products.

For further information on the laws on the environment that apply to our Company and the related information and procedures, please refer to the “Environmental Policy statement of MOBIAK SA” found on the company website and also posted in the public areas of our facilities.

Communication and Disclosure are Essential Matters

By accepting employment at MOBIAK SA, each of us is responsible to comply with these ethical standards, with all laws and regulations and detailed guidelines contained in the Business Practices Guidelines as well as with other policies, procedures and instructions of our Company and its subsidiaries. Employees are responsible to disclose these standards to the people with which they collaborate, ensuring they have been understood and complied with and thus creating an environment where people can discuss openly about any ethical or legal issues that may arise.

Monitoring of Compliance

Compliance to the Code shall be monitored by the Department Heads and the Managing Director.

Non-Retaliation Policy

No negative action will be taken against any person who submits complaints / reports, who participates or assists in the investigation of a possible violation of the Code of Ethics, unless that claim has been made based on information that is intentionally false. MOBIAK SA will preserve the confidentiality of all reports to the maximum extent possible.

Further, it shall not tolerate, and strictly prohibits, any retaliation against any person reporting issues or matters in good faith.

Seeking Guidance and Reporting Issues

This Code cannot give definitive answers to all questions. This is why, ultimately, we must rely on the common sense of each person on what is required to keep the high standards of the Company, including the common sense as to when to seek guidance on proper behavior.

In most cases, you must pose questions on the instructions described in this Code to your supervisor or the Managing Director.

Disciplinary Measures may be Imposed

Company policy is one of “zero tolerance” for any behavior which is in violation of the Code of Ethics or the Business Practices Guidelines. Thus, the Company will deter behaviors that do not comply with the Code or the Business Practices Guidelines and will stop any behavior that may take place, as soon as possible after its discovery. The people of MOBIAK SA who violate the Code or the Business Practices Guidelines, may be subject to disciplinary actions including their termination from the company.

The Code applies to all MOBIAK SA Activities

The Code applies to everyone who works for the Company MOBIAK SA – and its subsidiaries, including its executives and also applies to the directors of the Company and its representatives, in accordance with applicable legislation. Copies of the Code, available from the Personnel Department, must be given to all persons or entities that have been hired and are authorized to act on behalf of the Company in areas where the Code applies. Each year the Code is examined at the annual review of the company’s Quality System and revised as necessary. The Code also applies to partners and suppliers and compliance to the Code is a prerequisite for continued cooperation with MOBIAK SA.

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