Anti- Corruption & Bribery Policy

Thanopoulos S.A. is fully committed to maintaining the highest standards of transparency and ethics. This Policy outlines the principles and procedures for the prevention, detecting and combating incidents of corruption and bribery.

1. Zero Tolerance Policy  
Thanopoulos S.A. operates under a zero-tolerance policy towards any form of bribery or corruption. Any offer, promise, giving or receiving of money or any other benefit for the purpose of influencing business decisions is strictly prohibited.

2. Definitions
-Bribery: The offer or acceptance of any benefit in exchange for favourable treatment.
-Corruption: The misuse of authority or position for personal or corporate gain, contrary to ethical norms and applicable laws.

3. Applicability
All employees, suppliers, affiliates and third parties associated with Thanopoulos S.A. are subject to this Policy.

4. Obligations of Employees & Partners
-Reporting of any instance of bribery, real or suspected.
-Avoiding situations that may lead to conflicts of interest.

5. Control & Reporting Mechanisms
-The company uses approval procedures and internal control mechanisms
to prevent suspicious transactions.
-A secure and anonymous reporting mechanism is available to all employees and partners.
-All reports are carefully evaluated and handled with confidentiality.

6. Approved Activities
Certain types of gifts or business-related expenses may be considered acceptable provided that:
- They are not intended to influence decision-making.
- They are documented and submitted to the Commercial Department prior to acceptance.

7. Consequences of Non-Compliance
Violation of this Policy may result in disciplinary action, termination of cooperation and/or legal proceedings.

This Anti-Corruption Policy is subject to regular review and represents a core element of Thanopoulos S.A. corporate governance model.