Corporate Governance

Compliance with the legislation in force, the Code of Conduct and the internal Policies is of great importance to cosmoONE.

Ensuring Compliance is a priority of the Company’s Board of Directors.

Compliance stands for a solid commitment to the principles of integrity, transparency, justice, professionalism, team spirit, and of respect to the rules, principles which are essential to govern the functions of the Company.

On this purpose, the Management has adopted and implemented a Compliance Management System (C.M.S.), regarding the compliance of all (personnel and Management) with the legislation in force, with the Code of Conduct and with internal Policies, aiming to avoid risks and other legal consequences for the Company and its personnel. In so doing, the benefit is for all: the Company per se, the employees, the customers, the suppliers and the shareholders.
The effectiveness of the Compliance Management System relies on the commitment and the support of all: Management and employees.

The key elements of the C.M.S.are:

1.the prevention of misconduct in parallel with compliance with the policies provided for by the CMS.
both the company and its personnel are protected from any legal consequences due to misconduct, while the reputational risks of the company are reduced.
Prevention is achieved mainly through:

• The employee’s training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, manipulation of financial statements, leakage of confidential business information,e.t.c.
• The channels that have been developed for the communication with employees, so that the latter can submit questions regarding the implementation of the Code of Conduct and the Policies, in case they are uncertain as to how they should handle issues that come up in their daily work.

2.the detection of compliance violations and the response to them.

In order to provide the possibility of filing a tip – off regarding violations of Policies, regulations and of the legislation in force, the Company has established the Whistleblowing Policy and the relevant communication channels.
In the context of this Policy,employees or/and third persons may nominally or namelessly report to cosmoONE Compliance Officer a tip – off or express a concern or a complaint regarding potential violations of the Company’s Policies or the legislation. cosmoONE does not allow for any retaliation act on behalf of the management or other bodies of the Company, directly or indirectly against any person, who on good will, reports or expresses concern or complaint with regards to violation of policies or law.The implementation of the Company’s CMS is monitored by the OTE Group Compliance, Enterprise Risks & Corporate Governance Committee. OTE’s CMS has been successfully reviewed by independent external auditors, who confirmed the effectiveness of the compliance procedures.

Whistleblowing Communication channels:

You may file a tip off, addressed to the company’s Compliance Officer, via:

1.Mail: cosmoONE Hellas MarketSite S.A. 26 Olympias Str 14122,Heraklion, Athens
2.email: whistleblowing@cosmo-one.gr
3.Telephone: +30 210 2723810 (Monday through Friday: 9 am until 5 pm)
4.Fax: +30 210 2723820
5.Electronic Whistleblowing Form
The implementation of the Company’s CMS is monitored by the OTE Group Compliance,Enterprise Risks & Corporate Governance Committee. OTE’s CMS has been successfully reviewed by independent external auditors, who confirmed the effectiveness of the compliance procedures.

Please do not use these channels for reporting issues about products or services of the Company.
These issues should only be directed to Customer Support: support@cosmo-one.gr, +30 210-2723360, 801-11-15500.

Compliance Policies

In the context of implementation of the Compliance Management System, the following Policies and Codes are in force:

OTE Group Whistleblowing Policy

Aims at managing cases related to malpractices or improprieties and infringements of OTE Group/Company policies, procedures or applicable laws.

OTE Group Code of Conduct

The Code of Conduct is the framework for guiding the behavior of all people in the OTE Group of companies. Specifically, the Code confirms our commitment to consistently comply with the laws and regulations governing the operation of the OTE Group of companies, as well as with the requirements relating to ethical behavior, and supports the success of our Group.

OTE Group Code of Human Rights & Social Principles

The Company declares that complies with the applicable laws and strives to comply with the international standards so as not to violate human rights and, to this end, it has adopted and applies the “Code of Human Rights and Social Principles”.

OTE Group Supplier Code of Conduct

Based on the Company core values addressing business ethics, social and environmental commitments, the Company requires the Suppliers to adhere to the listed, at the Code, Principles, which will be attached to the contract entered between the Company and the Supplier. The Supplier shall do its utmost to implement these Principles through its whole supply chain.

OTE Group Code of Ethics for Senior Financial Officers

Defines the framework of conduct of the Senior Financial Officers, in order for honesty, integrity, transparency and ethical conduct by those persons to be promoted in the performance of their management responsibilities.

Binding Corporate Rules Privacy :These rules contain the necessary requirements for the processing of personal data of subscribers and employees in accordance with applicable Greek and European legislation and ensure the high level of protection of personal data.

OTE Group Policy on insider trading

This Policy sets the rules for non-abuse of privileged information by OTE Group executives and regulates the manner of subscription, acquisition or sale of securities from OTE Group companies.

OTE Group Policy on donations and sponsorships

This Policy guides OTE Group’s Companies on how to deal with sponsorships and donation issues.

OTE Group Policy on Accepting and Granting of Benefits

This Policy provides a description of the rules and regulations of conduct with regard to the acceptance and offering of benefits in business dealings.

OTE Group Fraud Policy

This Policy is established to facilitate the development of controls that will aid in the detection and prevention of fraud against OTE Group companies.

OTE Group Events Policy

This Policy describes the basic conditions, principles and rules of conduct to be observed in the conception, planning, execution and monitoring of events.

OTE Group Policy on Avoiding Corruption and other Conflicts of Interest

This Policy provides the framework for avoiding corruption and other conflicts of interest in relationships with customers and business partners.

OTE Group Policy on Avoiding Sexual Harassment within OTE Group

Target of this Policy is the prevention of sexual harassment acts, the awareness of managers and employees in relation with this issue, and the enhancement of confidence of employees regarding the support they shall have by their superiors in such cases.

OTE Group Policy on Employee Relations

This policy specifies the key elements of employee relations within OTE Group. It describes what we stand for in our relationship with employees in all countries where we operate.