Sanctions Policy & Report/Complaint Handling Procedure

We would like to inform you that until the special HEDNO electronic platform enters into service for receiving reports-complaints that fall within the object/scope of the HEDNO S.A. policy against violence and harassment at the workplace, as well as within the scope of the HEDNO S.A. sanctions policy and the procedure for managing reports and complaints, which were approved by No. 25/27.07.2023 Decision of the Board of Directors of HEDNO S.A.,  such reports-complaints may be submitted, in accordance with the provisions of article 4 of Annex I of the HEDNO S.A. sanctions policy and the procedure for managing reports and complaints, as follows:

(a)  They can be submitted orally by telephone or through other voice messaging systems, or, upon request by the reporting person, by means of a physical meeting with the person Responsible for Receiving and Monitoring Reports (RRMR) within a reasonable time frame. In such cases, the conversation shall be recorded, provided that the reporting person consents thereto, or the conversation or the minutes of the meeting shall be fully and accurately transcribed, in which case the reporting person shall be given the opportunity to verify, correct and agree with the text produced, by signing it.  If the reporting person refuses to sign, this shall be indicated by the author of the text, or

(b)   They can be submitted via a personal employee document or hierarchically to any Supervisor or directly to the RRMR, or

(c)   They can be submitted by mail at the Company address, i.e., HEDNO S.A., 20 Perraivou & 5 Kallirrois Str., PC 11743 Athens, for the attention of the RRMR with the indication “Confidential”, or

(d)   They can result from audits by the Internal Audit Department or the Compliance Officer or other audit body,

(e)   They can be submitted through an Authority (Greek Ombudsman, Hellenic Labor Inspectorate - SEPE, National Transparency Authority, etc.)

The reports sent in the manner described in points (a)-(d) above shall be forwarded to the Compliance Department and specifically the RRMR, they shall be registered on the platform by a designated user and shall be assigned a file code.

Reports sent through communication channels other than those specified above, as well as relevant reports in the press or online shall also be examined in accordance with the procedure set out in this Annex. 

The above reporting channels shall not be used for issues related to the Company’s products or services.  These issues should be addressed exclusively to the “Contact us” Company’s channel. 

In addition to the above, we would like to inform you that the person responsible for receiving and monitoring reports for the Company (RRMR), in accordance with article 9, Law 4990/2022, is the in-house lawyer of the Company, Mrs Antigoni Vafeidou, whose contact details are:

Antigoni Vafeidou

Address:  98-100 Syngrou avenue, 117 41 Athens

Telephone: 210 9090436

Email (in the context and for the purposes hereof): petitionspolicy@deddie.gr