MYTILINEOS

The purpose of this Code is to act as a set of guidelines that define the basic standards of ethical behavior of the values ​​and principles of Corporate Social Responsibility which, MYTILINEOS, expects from its key Partner Suppliers to adopt in their transactions employees, suppliers, contractors and their customers on its behalf.

In particular, the company expects from its supply chain to develop clear policies and procedures for respecting human rights and labor law, supporting local communities by recognizing and monitoring the risks of bribery and corruption, identifying and monitoring the negative environment and by developing policies and procedures governing the areas of Quality Assurance and Health and Safety in their businesses where possible.

The Code is addressed to key and new suppliers and partners of MYTILINEOS in all areas of its Business Activity.

The company urges the compliance of its existing key Suppliers / Partners with this Code, while taking into account, in evaluating the cooperation with them their progress in relation to the fulfillment of these requirements. At the same time, during the selection process of new Suppliers / Partners, MYTILINEOS defines the specific Code as a prerequisite.

Internal review on an annual basis, as it is a key element of the business model of the company.

MYTILINEOS is committed to operating in accordance with the principles of honesty and integrity. In this regard, the company seeks to develop and maintain business relationships with its key Suppliers and Partners, who will be able to share this commitment in the context of:

• Carrying out their business activities in a responsible manner, in compliance with the provisions of applicable law.
• Defending the rights of their employees in a safe working environment.
• Their compliance with environmental laws and regulations as well as the goal of reducing the environmental impact of their activities.
• The implementation of the management and monitoring of governance practices in order to ensure compliance with contracts and applicable law.

This initiative followed the following key stages of implementation:

• Basic mapping of the company's supply chain (categorization of suppliers by service they offer, by partnership with MYTILINEOS, by geographical origin, etc.)
• Study of the results of the process of determining the issues of Substance related to the supply chain.
• Initial configuration of the content of the Code based on the international methodology of the ESG (Environment-Social-Governance) criteria, which is the innovation in the structure of the Code.
• Consultation with the Sectors of Business Activity (TED), including the approvals of all Directorates-General, in order to agree on the ESG criteria in a general context.
• Final configuration of the structure and the content of the Code which was used as a basis for the creation of the individual Codes of the TED of the company which include the peculiarities of their supply chain depending on their activity.
• Publication and promotion of the Code. www.mytilineos.gr/Uploads/PRESENTATIONS/Suppliers_BusinessPartnersCodeofConduct_gr.pdf

The Code of Ethics of Suppliers and Partners of MYTILINEOS was developed internally utilizing the specialized scientific training of its executives in matters of Responsible Entrepreneurship.

The development process of the Code involved senior and top executives of all MYTILINEOS BUs.

MYTILINEOS headquarters in Athens

The development and maintenance of an efficient and quality supply chain is a commitment in which MYTILINEOS invests and will continue to invest at the level of permanent partnerships at national and local level. In this regard, the role of key partners and suppliers is a catalyst as it is an integral part of this effort.

The company's supply chain, in the individual sectors of its activity, has more than 5,000 suppliers with 81.7% of them based in Greece. The company invests more than € 700 million to its domestic suppliers each year, significantly benefiting local communities, indirectly contributing to both job creation and revenue generation.

In this context, the Code of Conduct for Suppliers and Partners promotes the concept of responsible entrepreneurship and consequently of sustainable development that should govern the supply chain of MYTILINEOS. Through the dissemination of the Code and the implementation of control procedures for its compliance, the company is informed about the significant real and potential negative effects of its supply chain on Labor, Environmental and Social issues. Recognizing any such significant effects allows the company to deal with them.

In 2017, the process of informing the key suppliers and partners about the Code of Ethics continued, while, within 2018, the first official evaluations of the new and key suppliers will follow.

There are several reasons why MYTILINEOS aims to promote responsible growth in its supply chain. These include ensuring compliance with laws and regulations as well as adhering to and upholding international principles for sustainable business conduct. In addition, the company is taking more and more actions and initiatives that lead to better social, economic and environmental performance, combining business benefits on many levels. More specifically, the systematic management of the Essential issues of responsible entrepreneurship related to the supply chain of MYTILINEOS, as stated in the Code, will work positively in the fulfillment of its business objectives, in the better prevention of risks and recognition of opportunities, in the requirements of its Social Partners and in the interests of society at large.