MYTILINEOS, as a responsible business citizen, fully integrates in its activity the regulatory framework defined by both Greek and European legislation, as well as the international forums in which it participates.
According to the Market abuse Regulation and the Hellenic Capital Market Commission, Persons discharging managerial responsibilities in MYTILINEOS, as well as persons closely associated with them, shall notify MYTILINEOS and the Hellenic Capital Market Commission on their transactions regarding MYTILINEOS securities within a three day period.
Compliance retains a catalogue of all persons discharging managerial responsibilities, that includes persons/ legal entities closely associated with them, and informs them regularly about their obligations and the blackout periods before the announcement of the financial results.
MYTILINEOS expects that all its partners hold similar standards of integrity when acting on its behalf. For this reason MYTILINEOS has established a detailed process of business partner compliance due diligence for certain types of cooperations.
The business partner is actively cooperating with MYTILINEOS and provides all necessary documentation/ information, as required, before any contractual agreement is made. After the collection process has been completed a Compliance Officer is checking the due diligence for completion and remaining red flags and sends the recommendation to the responsible Manager that shall approve or decline the cooperation. Any cooperation is then monitored for red flags during its duration.
MYTILINEOS S.A. (the company) encourages the use of the available corporate (internal) reporting channels to ensure timely review and appropriate management attention.
Whistleblowing reports through the corporate MYTILINEOS S.A. whistleblowing channels, can be submitted by employees linked to the Company by any type of current, former, candidate employment relationship, as well as any person working under the supervision and direction of contractors, subcontractors and suppliers of MYTILINEOS S.A.
Our company takes all appropriate technical and organizational measures to ensure Personal Data Protection, confidentiality, and protection of the whistleblowers from any form of retaliation under the conditions of the Greek laws 4990/2022 and 4808/2021.
The Whistleblowing procedure should not be abused with the submission of ill-considered accusations or personal complaints. To prevent the submission of malicious or unsubstantiated reports, sanctions may be imposed on employees who have acted in bad faith. In such cases, the laws on defamation in force in the countries where the Company operates shall apply.
What should be reported
Topics that fall under the scope of the Greek Law L.4990/2022 (public procurement, financial services, products and markets, including the prevention of fraud, corruption and other illegal activities and the prevention of money laundering and terrorist financing, product safety and compliance, transport safety, environmental protection, public health, consumer protection, protection of privacy and personal data, as well as the security of network and information systems, radiation protection and nuclear safety, food safety, animal health and welfare), issues affecting the financial interests of the Union, issues related to the free movement of goods, persons, services and capital, as well as issues concerning the Greek Law L.4808/2021 on the matters of Prevention and Combating Violence & Harassment at Work.
Available Channels to submit a Whistleblowing report.
The Whistleblower shall receive an acknowledgement of receipt of the report within seven days of its submission, as well as information on the actions taken by the competent bodies of the Company within three months of the submission of the report.
The submission of Whistleblowing reports through the communication channels #1 & #2 takes place in an environment of complete confidentiality, and, at the choice of the Whistleblowers can be done anonymously. After submission through channel #1, the Whistleblower receives a unique identifier from the Whistleblowing platform so that he/she can later log into the virtual mailbox of the Whistleblowing platform and answer questions raised by the evaluation team or be informed about the progress of his/her report. Through channel #2, communication with the whistleblower is performed through email without disclosing the whistleblower’s email address to the Company.
Individuals may also submit reports to external whistleblowing channels operated by the National Transparency Authority (NTA) as per law 4990/2022. https://aead.gr/submit-complaint