Code of Business Conduct of HELLENIC PETROLEUM GROUP

The goal is the practical implementation of the Group's vision, to pioneer as a regional energy company, with the sustainable development being a critical aspect of its business strategy. Through the Code of Business Conduct, consistency and continuity of the Group's operation is assured, in addition to the protection of the company’s interests not only for subsidiaries or affiliate companies, but also for companies that cooperate with the Group, by setting binding rules and instructions, aiming to the conduct of their activities based on legality and business ethics.

• Management and employees of the Group.
•  Group's external partners and suppliers.

The Code of Business Conduct was introduced on 2012 and is of indefinite term.

The Code of Conduct was introduced with the main purpose to clarify the fundamental principles and values that rule the way of operation and business activity of the Group’s companies, in Greece and abroad. It was drafted taking into consideration the specific needs of the Group and also the experience of other big organizations. The Code of Conduct requires compliance to legislation and competition laws, appropriate management of group’s internal information, physical or intellectual property, accuracy of financial information and sets the basic principles for the protection of environment, sustainable development and social responsibility. It strictly prohibits activities that are characterized as actions of corruption, extortion, bribery, money laundering and establishes the framework in order to prevent conflicts of interest, and forms the relationship between the group and its employees, which is governed by meritocracy, equal opportunities and respect. It, also, emphasizes through relevant references the need for increased protection of employees’ health and safety and the obligation to apply all of the Group's specific safety procedures. The implementation of the Code of Conduct is mandatory for the top management team, all employees and partners of the Group, while a regulatory compliance office is available and responsible to resolve questions, investigate complaints and to finally implement the Code of Conduct in general.

Not applicable

The Code of Business Conduct is obligatory for all employees who have both the right and obligation to report any facts that constitute violation against it. It, also, includes obligations for the management of the Group and its external cooperators.

In all installations of the Group both in Greece and abroad and external partners.

During the applicaton of the Code of Business Conduct, the Regulatory Compliance Service has investigated reports for issues related to its content, mainly regarding issues of conflict of interest, and has given advice so as to avoid breaches of the Code. The extended educational programs about the application of the Code of Business Conduct are helping the Group to realize to a significant extent the importance of the Code. The Code of Business Conduct has been translated to the local languages of the countries where HELPE group maintains operations, resulting to its extensive application. The external cooperators of the Group have also received the Code of Business Conduct, along with a letter that stresses its obligatory character and the importance of its application for the continuation of the cooperation with the Group. Due to the wide range of the Group’s activities and the extent of its cooperation with third companies, the effect of the Code’s application towards the formation of a legality and business ethics conscience, is considered significant.

The benefits for the company concern not only the legitimacy and consistency of its activities but, also, the support of the Group's principles and vision.