The following Policies and Codes apply in the context of implementing the Compliance Management System:

OTE Group Code of Conduct

Our 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. In conjunction with the five Guiding Principles it supports the success of our Group.

Awareness on sustainability issues for suppliers

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 Code of Ethics for Senior Financial Officers

This Code 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.

OTE Group Whistleblowing and Non-Retaliation Policy

The OTE Group Whistleblowing and Non-Retaliation Policy sets the framework for the adoption of a reporting system in OTE Group companies regarding violations of corporate policies and procedures, regulations and applicable legislation, including breaches of Union law, describes the process regarding the submission, receipt and monitoring of reports and provides an integrated framework for the protection of persons who report breaches related to the above-mentioned matters.

Binding Corporate Rules Privacy

These rules contain the necessary requirements for the processing of personal data of both the customers and the employees of OTE Group in accordance with applicable Greek and European legislation and ensure the high level of protection of personal data.

OTE Group Policy on Insider Trading

The Policy on Insider Trading describes the responsibilities and obligations of the Employees of OTE Group regarding the Inside Information.

OTE Group Policy on Anti-Trust Law

The Policy on Anti-Τrust Law describes the operational framework in the context of antitrust law for the activities of OTE Group of Companies and its employees. It sets down corresponding operational guidelines for employees who conduct discussions or negotiations with competitors, suppliers or customers that have the potential to restrict the competitive freedom of action of OTE’s Group of Companies, its contractual partners or third-party companies.

OTE Group Donation Policy

The Donation Policy defines the specific transparent and mandatory procedures to be followed by OTE Group companies when assessing and implementing Donations, based on the action areas defined by the Sustainable Development strategy.

OTE Group Sponsoring Policy

The Sponsoring Policy describes how to deal with Sponsorship issues by setting out clear criteria for implementing the procedure which needs to be followed by the OTE Group companies in order to carry out Sponsorships, ensuring transparency regarding the efficient use of resources allocated for Sponsorships.

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 Anti-Fraud Policy

The Anti-Fraud Policy provides a description of the rules and the basic guiding principles with regard to the fraud incidents that may occur at OTE Group companies and it sets the necessary measures for the prevention of such fraud cases.

OTE Group Event Policy

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

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.

Policy on Employee Relations within OTE Group

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.

OTE Group Sustainability Policy

This Policy sets out the Sustainability strategy and the action plans for OTE and its affiliates, taking into consideration the social and financial circumstances as well as the culture priorities and challenges.

OTE Group Supplier Code of Conduct

Based on the Company’s 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.

Policy on Concluding Transactions with Related Parties

This Policy describes the method with which the Company handles issues regarding transactions with Related Parties, in compliance with current legislation.

Risk Appetite Statement

The Statement defines the level of risk OTE Group undertakes in pursuit of its strategic goals.

OTE Group Diversity, Equity & Inclusion Policy

This Policy promotes the values of Diversity, Equity & Inclusion in the workplace (DE&I).

Policy on Avoiding Sexual Harassment within OTE Group

This Policy outlines the framework for managing any form of violence

and harassment in the workplace in accordance with law No. 4808/2021

on labor protection and other provisions.

Digital Ethics Guidelines on Artificial Intelligence OTE Group

Digital Ethics Guidelines on Artificial Intelligence OTE Group, set the rules that we need for the work of our developers and designers and for when we collaborate with suppliers and partners. They also provide legal certainty when it comes to the handling of AI products and services. Εach and every guideline is a statement and a promise: for taking on responsibility, for transparency, for data privacy, security, for self-determination in terms of data and for consumer protection.