ANTI-BRIBERY AND CORRUPTION POLICY

1. ANTI-BRIBERY AND CORRUPTION POLICY STATEMENT

1.1 *********is committed to conducting its activities in accordance with the highest ethical
and legal standards. The integrity of our employees, as well as our partners, is important to
our success.

This statement of our anti-corruption policy was drafted taking into account the rest of
them, to underline the position of********** on matters of bribery and corruption and to
offer information and guidance on identifying and dealing with such phenomena.

1.2 ********** applies a zero-tolerance policy for bribery and corruption and is committed
to acting with professionalism, legality and integrity in all its business dealings and
relationships wherever it carries them out. To achieve this, ********** . is committed to
implementing and enforcing effective anti-bribery systems, in accordance with all relevant
Greek laws (such as the Incorporation Laws 2656/1998, 2802/2000, 2803/2000, 2957/2001,
3506 -as amended by Law 4254/2014- of the European Union as well as the Conventions and
Regulations of the United Nations), the US Foreign Corrupt Practices Act of 1977 and its
amendments, as well as the laws in force in the countries in which the company operates, to
the extent that these laws are enforced.

1.3 ********** does not tolerate any form of bribery or corruption. ********** will not
provide, offer, or offer to provide, authorize or require anyone to provide, directly or
indirectly, influencing of any kind to persons, so that such persons proceed, violate their
duties, in or omission. ********** will never solicit or accept, directly or indirectly, may
induce or cause or survive improper conduct in the form of acts or omissions arising out of
or in conflict with one's duties.

1.4 In this Policy Statement, "third party" means any natural person or organization
employee who, in the course of performing their duties, comes into contact with
********** . and includes actual and potential customers, information, suppliers,
distributors, business contacts, agents, consultants as well as government and public bodies,
including their advisers, agents, senior employees, politicians and political parties.

2. WHO IS COVERED BY THE POLICY

2.1 The fundamental standards of integrity under which ********** operates. remain
unchanged, regardless of where it carries out its activities or with whom it cooperates.

2.2 This Policy applies to all persons regardless of the level at which they work and the title /
rank they hold, including senior managers, senior employees, directors, members of
Executive Committees and Boards of Directors, employees (permanent, with fixed-term or
temporary contract), consultants, contractors, trainees, seconded employees, volunteers,
interns, agents, sponsors and any other person related to ********** any of its subsidiaries
or their employees, wherever the their headquarters (collectively referred to as “personnel”
for the purposes of this Policy).
2.3 This Policy sets a standard to which all staff must comply, regardless of whether local
laws, customs or practices dictate otherwise.

2.4 Failure to comply with this standard, willfully or involuntarily, may lead to disciplinary
proceedings which may result in dismissal due to serious misconduct as well as criminal
prosecution of the person involved, under the relevant Greek laws.

2.5 This Policy does not form part of any staff employment contract and may be amended at
any time.

3. WHAT IS A BRIBE?

Bribery includes the following:

When a financial, or other, advantage is offered, or favored, to another person, with the
proposal to entice or reward him to perform his duties improperly, or

When it is a financial, or other advantage, agreed to be received or accepted by another

person to perform their duties improperly.

It does not matter if the bribe:

Given directly or through a third party, or

It is given for the benefit of the recipient or another person.

4. GIFTS AND HOSPITALITY

4.1 ********** recognizes that in many places gift-giving is considered a ceremonial way of
establishing closer personal relationships or showing gratitude for a service rendered.
However, according to this Policy, ********** she is particularly cautious about giving or
receiving gifts.4.2 While formal gifts are usually considered acceptable, gifts deemed
excessive, extravagant or in any way inappropriate will not be offered or accepted. In any
case, the intention behind the offer of the gift will be taken into account. Money or other
similar gifts will not be accepted as gifts.

5. DONATIONS

**********. does not contribute to any political party. Charitable donations will not be
given for the purpose of gaining a commercial advantage.

6. RAISING CONCERNS

Staff recommended to report concerns with any issue or suspected wrongdoing as early as
possible. No employee will be harmed for raising genuine concerns about bribery,
corruption, money laundering, improper donations and facilitation payments.

7. MONITORING AND REVIEW

7.1 The effectiveness of the implementation of this Policy will be monitored and evaluated
regularly, regarding its appropriateness and work. Improvements deemed necessary will be
implemented as soon as possible.

7.2 All staff members are responsible for the success of this Policy and should commit to
implementing it to uncover potential risks or wrongdoing.

7.3 Staff will be invited to comment on this Policy and suggest ways to improve it.
Comments, suggestions and questions should be directed to representatives of the legal
department.