Section ECONOMY
TOPIC

HELLENIC PETROLEUM

Competition Policy Action and Compliance Manual

Maintaining high ethical standards regarding the compliance with national and international law, as well as the belief in the need for their rigorous application constitute fundamental principles of Helpe Group and govern all of its individual activities in each country in which it operates. In view of its international activity, the Group believes in the need to comply with at-the-time applicable national, European and international law, including the Greek and European free competition laws and the relevant laws of the countries in which the Group operates (eg Cyprus, Bulgaria, etc.). Given the complex and distinctive characteristics of the markets that the Group is active, compliance with Competition Law requires continuous information on these markets and their developments, belief in the need to respect the laws in general, as well as vigilance, consistency and conscientiousness. The Competition Policy aims at a complete understanding by all the employees of the Group and its external partners of the Competition Law’ provisions and  at the full compliance of the Group with the Greek and European competition law, as well as with the national legislation of the countries in which it operates.

The policy is applicable to members of the Board of Directors, executives, employees and generally any person providing services to the Group, without any exception or derogation.

Indefinite

The Policy consists of two main sections. The first section depicts the Competition Policy of the Hellenic Petroleum Group and its unconditional commitment to comply with the requirements of the Greek and European competition law, as well as the national competition laws of the countries in which it operates. The ultimate goal of the Group's Competition Policy is the comprehension of the potential contradictions to the provisions of competition law and the creation of appropriate knowledge on how to avoid them at all levels of the Group, from employees to middle and senior management.

The second section depicts the more specific Compliance Program of the Group to these laws. Its purpose is to inform the Group's people about the basic provisions of Greek and European competition law, the rationale that governs them, the practices they prohibit and the sanctions that are provided, as well as the Administrative Authorities that are responsible for their application. This information is intended to assist both the Management and the employees of the Group to understand not only the fundamental rules of Competition Law, but also the impact of these rules on the day-to-day operation of the Group and on the formation of its business practices. Such an understanding is necessary in order to prevent any breaches of competition law that may expose the Group and any individual employee to the risk of severe sanctions.

At the same time, the policy aims to inform and sensitize the staff of the Group regarding potential or actual malpractice of the customers, suppliers and / or the Group's competitors, contrary to competition law.

The last section of the Policy sets out the mechanism and procedure to be followed, in the event of violation of competition rules or in case of a relevant suspicion.

The Policy has been developed in collaboration with legal counsels specialized in topics of competition. 

Each and every employee in the Group, regardless of hierarchy, is individually responsible for adhering to the Group's Competition Policy and complying with competition rules. 

Hellenic Petroleum Group of Companies

The executives and employees of the Group that often deal with competition issues at   daily work, will participate during the next two months in a training program, in order to fully understand the rules of competition and ensure their implementation in the day-to-day operation of the Group and its business activities.

Assurance of the legality of the Group's business activity, which has a key role in its sustainable development.