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Transparency

We believe in full Transparency.

At Sunlight Technosystems, member of Sunlight Group, we conduct business with the highest standards of corporate governance and ethical behavior. Our Code of Conduct reflects our commitment to operating in full transparency and compliance with applicable legislation, rules, and regulations. This commitment governs our relations with customers, investors, partners, suppliers, employees, regulators, and authorities.

The Code of Conduct document is structured around our shared values: Innovation, Agility, Integrity, Value Creation, and Data-driven. It is based on the principles of respect for human rights, transparency, accountability, and accuracy. And it guides the entire Sunlight Group Ecosystem in protecting the company’s reputation, assets, and brand.

Sunlight Technosystems’ Code of Conduct describes how we operate, ethically and transparently, to achieve our goals’ purpose. Because for us, the way we achieve results is just as important as results themselves.

 

The Sunlight Technosystems policies

Ensuring compliance with the legal, regulatory and supervisory framework, as currently in force, is a priority for Sunlight Group of companies.

To that end, Sunlight Technosystems has adopted the following Compliance Policies and Procedures, aiming to protect the company and its personnel from any negative consequences due to misconduct, which could significantly damage its reputation and harm the trust that has been established with its employees, customers, suppliers and the communities where it operates.

The Compliance Policies are approved by the Group Compliance Committee and are binding to all companies of the Sunlight Group. The Compliance Function is responsible for their development and update, while their effective implementation is up to all Group’s personnel and management.

For more information about our policies, please contact: compliance@sunlight.gr  

 

At Sunlight Technosystems, we conduct business with the highest standards of corporate governance and ethical behavior.

All our policies

Sunlight Technosystems Code of Conduct

Sunlight Technosystems strives to provide excellence in every aspect and level of its organization. Our Code of Conduct provides practical advice for our employees on laws and regulations, expectations, best practices and guidance on dealing with others. It’s a reflection of our commitment to operating with integrity, transparency, fairness and in full compliance with applicable laws and ethical principles.

 

  • Anti-Bribery Policy

Through this policy, Sunlight Technosystems seeks to ensure that all employees, as well as third parties, with which it conducts business, comply with the main anti-bribery regulations and legislations applicable to the different jurisdictions where they are operating. Establishing appropriate rules and processes to prevent corruption and facilitation payments and raising awareness to its personnel in such matters is of outmost importance for Sunlight Technosystems for safeguarding a transparent working environment. The policy, the basic principles of which are included in the company’s Code of Conduct (Chapter 5- Individual Conduct), endorses the basic principles set in international standard ISO 37001, on Anti-Bribery Management System.

 

  • Donations & Sponsorships Policy

Sunlight Technosystems develops a proactive and ongoing strategy to support the needs of the communities it lives and thrives in. In this context, it annually grants donations and sponsorships to entities, for the purposes of improving the quality of life of local communities, supporting education and training activities or  environmental initiatives and enhancing health, emergency and rescue services.

The Donations & Sponsorships policy sets the specific transparent and mandatory procedures to be followed by the company when assessing and granting donations or sponsorships based on the action areas defined by the Group Corporate Affairs & Sustainability Department’s strategy.

 

  • Gifts & Hospitality Policy

Sunlight Technosystems recognizes that gifts and hospitality can be important for developing business relationships with customers, suppliers, and other third parties. However, they may often raise suggestions of impropriety. Therefore, it is important that employees are able to assess whether a gift and hospitality received or offered is accepted or prohibited. If not prohibited, employees need to ensure that the internal gifts and hospitality procedure is followed.

This policy provides guidelines for the appropriateness of different kinds of gift and hospitality and sets specific procedures to be implemented when offering or receiving such items during business dealings.

 

  • Policy on Preventing and Addressing Violence and Harassment at the Workplace

Target of this policy is to promote diversity and inclusion and ensure a working environment with zero tolerance to violence, bullying, discrimination and harassment, based on the principles of mutual respect, human dignity, cooperation, mutual assistance and the protection of human existence and human rights.

Sunlight Technosystems adopts appropriate measures to prevent and combat any kind of violence and harassment, expressly including sexual harassment, at work, and establishes effective and confidential internal reporting mechanisms to encourage all employees to speak up, without the fear of victimization or retaliation.

 

  • Competition Policy

Through this policy, Sunlight Technosystems commits to comply with the rules of Greek and European Union competition law, as well as those of the national competition laws of the countries within which they operate. As some agreements with customers, suppliers, competitors or other business partners can potentially limit free and open competition, it is important to make sure that all employees involved in commercial activities and conducting discussions and negotiations with third parties know how to apply antitrust rules and to avoid even the appearance of unfair restriction of the competitive freedom.

This Policy enhances employees’ awareness about competition best practices and rules, defines and prevents prohibited agreements and establishes measures appropriate for preventing abuse of dominant position, promoting a healthy and fair competition with other industries activated in our area of specialization.

 

  • Sanctions Policy

The present policy outlines the controls and procedures required to be in place in order to ensure that Sunlight Technosystems comply with all applicable economic, trade and financial sanctions laws and regulations. It addresses the risk of Sunlight Technosystems entering into a transaction with a sanctioned entity in breach of sanctions legislation, which could potentially result in reputational damage, large fines or criminal penalties for individuals, restrictions on the ability of the company to engage in international business transactions or even termination of the company’s financing arrangements.

 

  • Third Parties’ Due Diligence Policy

The cooperation of Sunlight Technosystems with suppliers, customers, agents and other business partners is assessed in accordance with approved (qualitative and quantitative) criteria. The Third Parties Due Diligence Policy describes in detail the above criteria and the exact steps of the due diligence process, that Sunlight Technosystems needs to perform prior to establishing relationship with any third party, as well as on a regular basis during their collaboration, with the objective to identify the level of compliance of business partners with applicable laws and regulations, corporate best practices and main values and principles, as endorsed in the company’s Code of Conduct.

 

  • Conflict of Interest Policy

Although Sunlight Technosystems respects its employees’ right to privacy in their personal affairs and activities, it implements all measures and procedures required to effectively identify and then manage any case where the personal or family activities of the latter raise or may raise an actual or potential conflict with their duty of loyalty to the company.

 

The present policy aims to prevent, detect and manage the conflicts of interest that may arise between Sunlight Technosystems and its workforce. Through ensuring employees’ objective judgement and commitment to the business goals, we protect the integrity of the decision-making process and thus the company’s reputation and stakeholders’ trust.

 

  • Whistleblowing Policy

In order to enhance transparency and integrity, Sunlight Group of companies share common appropriate internal channels for handling and investigating reports and complaints. Read more here.