Lamda Development bases its operations on a modern and effective governance model that supports its efficient and sustainable operations.
In this context, the Company's governance model has been structured to adopt practices to promote transparency and accountability, developing a framework of principles that responds to the dimensions of Sustainable Development, the analysis of opportunities, risks and qualitative/quantitative objectives for its main activities. At the same time, practices for developing a dialogue (Stakeholder Dialogue) with all its stakeholders (Stakeholders & Shareholders), as well as rules and procedures for implementing a Sustainable Development strategy and linking it to the essential issues of the Organization are applied.
The Company has established and operates Management Committees, such as the Management Committee and the Investment Committee, which aim to support the Management in matters of its responsibility, monitor the progress of corporate affairs and take the necessary decisions in accordance with their approval limits, as well as a Report Management Committee, which has undertaken the management and investigation of reports.
In addition, Committees have been established to assist the Management in matters relating exclusively to The Ellinikon project, such as the Legal and Licensing Committee and the Project Executive Committee. The responsibilities of the Management Committees are included in the Company's Internal Operating Regulations.
The Group's basic principle is to respect and comply with applicable laws, provisions and regulations, as well as with the Corporate Governance Law for listed companies. For LAMDA Development, it is the individual responsibility of all employees to be informed of the applicable laws and regulations relating to their work and duties. The Group is in compliance with the provisions of Art. 1-24 of Law 4706/2020 and has adopted the Greek Corporate Governance Code (2021), which was issued by the Greek Corporate Governance Council, with the only deviation being a Special Practice.
The Group has a Regulatory Compliance Unit (RCU) whose main task is to establish and implement appropriate and updated policies and procedures, in order to achieve full and continuous compliance of the Group with the applicable regulatory framework in a timely manner and to have a complete picture of the degree of achievement of this objective at all times.
The key principles ensured by the RCU are:
- Business ethics.
- Transparency.
- Integrity.
- Safeguarding the interests of shareholders.
- Protection of those dealing with the Group.
The responsibilities of the RCU include prevention, suppression/detection and response actions in relation to matters within its competence, based on the Compliance Policy and the Compliance Procedures Manual.
A Whistleblowing Policy has been developed, which is available on the website https://www.lamdadev.com, under which a comprehensive whistleblowing mechanism has been adopted to enhance the transparency, accountability and integrity of the Group and to protect its interests and reputation.
The Group has developed a number of individual policies and procedures for the internal allocation of responsibilities regarding the way reports are submitted, managed and investigated:
- The Reporting Procedure, which establishes the reporting channels and describes in detail how employees and external partners are to submit reports.
- The Reporting Management Procedure, which defines competent bodies and the individual steps for the correct and effective management of reports.
- The Internal Petitions Investigation Policy and Procedure, which sets out how petitions should be investigated.
Within the framework of the aforementioned mechanism, a new customized platform (https://lamdadev.sec.fraudline.gr/) was created for the submission of reports exclusively for the Group, which in combination with the relevant email ([email protected]) constitute the integrated mechanism for the submission, management and investigation of reports. It is worth noting that the Group treats with due seriousness, confidentiality and attention all reports (whether anonymous or anonymous) submitted through the aforementioned statutory reporting channels.
Since the beginning of its operation, the Group has adopted a corporate culture with values and rules of conduct characterized by integrity, ethics, transparency and personal responsibility for each employee.
At the same time as complying with the applicable legislation and regulatory framework, all employees must comply with the Internal Operating Regulations, approved by the Board of Directors, the Code of Conduct, as well as the Policies and Procedures established by the Management. The Principles, Codes, Procedures and Policies that are applicable and available - where applicable on the website and intranet (either in Greek and/or in English), cover issues such as anti-corruption, conflicts of interest, personal data, confidentiality, customer relations, market abuse, management of privileged information, discrimination in the workplace, etc.
The ultimate goal is to conduct business and transactions with professionalism, integrity and fairness. Specifically, issues such as integrity and respect in labour relations, employee commitment to corporate objectives, commitment to continuous professional training of its human resources, as well as the continuous effort of employees to achieve maximum performance and continuous improvement of their work performance are covered.
The Code of Conduct governs the conduct of all the Group's human resources, including the members of the Board of Directors and Management. In particular, it includes provisions on corporate values (see the section "Code of Conduct" - "Our Values") and the Group's basic operating principles, such as integrity and respect for labour relations, compliance with applicable legislation, and the fight against corruption.
The application of the provisions of the Code of Conduct is mandatory and subject to review by the Group's competent supervisory bodies. To this end, the persons responsible for its implementation must familiarise themselves with its contents and sign the relevant acceptance form, which is handed over to the Human Resources Directorate.
The Group fully complies with the obligations arising from the legislation on data protection, such as, but not limited to, the General Regulation on Personal Data, Law 4624/2019 and the guidelines, as well as the relevant decisions of the Hellenic Data Protection Authority. In addition, it has taken all appropriate technical and organisational measures for the lawful processing of personal data, as well as to ensure the confidentiality, integrity and availability of such data.
The Internal Audit Department is an independent organisational unit within the Group. The Head of Service reports operationally to the Audit Committee and administratively to the Chief Executive Officer. The purpose and mission of the Internal Audit Service is to provide independent, objective, assurance and advisory services, designed to add value and improve the operations of the Group and its subsidiaries. The Service helps the Group to achieve its objectives by adopting a systematic professional approach to assessing and improving the effectiveness of its risk management processes, as well as its internal control and corporate governance systems.
The Group has established a Risk Management Unit, whose main mission is to contribute to the development of a modern operating framework at all organizational levels for the identification, assessment and management of the risks faced by the Group. The Risk Management Unit ensures that the risks assumed by the Directorates are in line with the risk appetite and tolerance limits set and established by the Senior Management. The Risk Management Policy, as well as the Risk Appetite Statement were formally approved by the Board of Directors in December 2022 and are applicable to the entire Group.
The objectives of the Unit are:
- To strengthen the Group's risk management culture.
- Contribute to the process of identifying, recording, assessing and managing risks at all levels and functions.
The Group has established the following policies and regulations:
- Internal Rules of Procedure
- Code of Conduct
- Supplier Code of Conduct
- Reporting Policy
- Performance Evaluation Policy
- Car and Fuel Policy
- Sustainable Development Policy
