Business Ethics Code

PAPAYIANNI BROS S.A. company has adopted a Business Ethics Code (hereinafter Code), which has been approved by the Management and is binding for all members of the Management, the executives, the staff, as well as its partners (suppliers, customers, subcontractors, etc.). The Code has been based on the OECD Guidelines for Responsible Business Conduct, the UN Guidelines on Business and Human Rights, as well as other recognized sources that promote business ethics, and includes fundamental principles and values as presented below:

1. Work must be a free choice

1.1. There should be no forced labour, slave labour or involuntary labour.
1.2. Employees are not required to provide original identification documents to their employer and are free to leave their employer after (reasonable) notice.

2. It is a moral obligation to respect the freedom of association and the right to collective bargaining

2.1. Workers, without any discrimination, have the right to join or form trade unions of their choice and to bargain collectively.
2.2. The employer adopts an open attitude towards the activities of trade unions and their organizational activities.
2.3. Employee representatives are not discriminated against and have access to perform their representative duties in the workplace.
2.4. Where the right to freedom of association and collective bargaining is limited by law, the employer should facilitate the development of parallel means for independent and free association and collective bargaining.

3. Continuous improvement of working conditions, by promoting a mindset of occupational risk prevention

3.1. Continuous efforts should be made to provide a safe and healthy working environment, taking into account prevailing industry knowledge and any risks. The appropriate measures to prevent accidents and hazardous health conditions should be taken, in order to minimize to the maximum extent possible, the inherent risks in the working environment.
3.2. Employees should receive regular and evidence-based health and safety training from qualified trainers.
3.3. The company must have at least the necessary infrastructure, covering the basic needs of employees during their work (break area, lockers, etc.)
3.4. The company, complying with Community and national requirements, should assign the responsibility for health and safety to legally competent management representatives.

4. Child labour is prohibited.

4.1. The company must not hire minors (<18 years) to work for the company.
4.2. The company promotes participation and contribution to programs aimed at helping any child found to be performing child labour to transition and to be given the opportunity to attend and remain in quality education until adulthood.
4.3. Children and young people under the age of 18 should not be employed during the night.
4.4. These policies and procedures must be in accordance with the provisions and rules of the relevant International Labor Organization (ILO).

5. Adequate remuneration is provided

5.1. Wages and benefits paid for a typical work week must meet, as a minimum, the national statutory or industry reference standards (whichever is higher). In any case, the salary should always cover basic needs and provide some disposable income.
5.2. The process of recruitment, payroll and job position responsibilities description should be done with absolute clarity and transparency.
5.3. All disciplinary actions must be recorded and implemented in accordance with applicable law. Any form of salary withholding without the express consent of the employee is prohibited.

6. Compliance with working hours based on employment contracts

6.1. Working hours must comply with national legislation, collective agreements and provisions 6.2 to 6.6 below, whichever provides the greatest protection for workers. Sub-clauses 6.2 to 6.6 are based on international labour standards.
6.2. Working hours, excluding overtime, are determined by contract, and must not exceed 48 hours per week.
6.3. All overtime must be voluntary and not used as a substitute to regular employment. Overtime must always be paid at higher rates, which are recommended to be no lower than 125% of regular pay.
6.4. The total number of working hours in any period of seven days shall not exceed the limit of 60 hours, except for the cases covered by clause 6.5 below.
6.5. Working hours may exceed the limit of 60 hours in a seven-day period only in exceptional cases, provided that all of the following are met:
this is permitted by national legislation,
this is permitted by a collective agreement of free bargaining with an organization of workers representing a significant part of the workforce,
appropriate guarantees are taken to protect the health and safety of employees,
the employer can demonstrate that there are exceptional circumstances, such as unexpected peak production, accidents or emergencies.
6.6. Employees must take at least one day off in each seven-day period or, where permitted by national law, two days off in each 14-day period.

7. Regular work is provided

7.1. To the extent possible, the work performed should be based on a recognized employment relationship documented through national legislation and practice.
7.2. Obligations to employees under labour laws and regulations or social security laws and regulations, arising from the regular employment relationship, through exclusively service contracts, subcontracting or working from home arrangements, or through apprenticeship schemes, where there is no real intention to impart skills or provide regular employment, must not be avoided, nor should any such obligations be avoided through excessive use of fixed-term employment contracts.

8. Any form of discrimination is prohibited and gender equality is promoted

8.1. There should be no discrimination in hiring, compensation, access to training, promotion, firing or retirement based on sex, national or racial origin, religion, age, disability, marital status, sexual orientation, union membership or political beliefs.
8.2. Gender equality and equal opportunities for all in the workplace should be non-negotiable. Fair practices that promote gender equality may include:
8.2.1. The presence of women in high-rank positions.
8.2.2. The offer of work according to the candidate’s abilities and regardless of gender.
8.2.3. Awareness of employees’ additional roles (parents, pregnant women, etc.).
8.2.4. Supporting the equal and meaningful participation of women in consultations and negotiations
8.2.5. Adoption of policies aimed at eliminating any form of violence that the employee may face in the workplace (verbal, sexual, gender-based).
8.2.6. Participation in training programs aimed at raising staff awareness in equality issues.
8.2.7. The formation of a committee, responsible for the implementation, monitoring and evaluation of measures that promote gender equality and the empowerment of women, in which a woman or women, also, participate.

9. Any form of exploitation and inhumane treatment is prohibited

9.1. A people-centered approach should be adopted, setting human beings as the company’s supreme resource.
9.2. Any form of abuse or blackmail (physical, verbal, sexual, harassment, psychological, etc.) that harms the dignity of any employee is condemned.
9.3. The provisions of this Code constitute the minimum necessary ethical standards, and cannot prevent companies from exceeding these standards. Rather, it urges companies implementing this Code to comply with national and other applicable laws and, where the provisions of the Law and this Code refer to the same subject matter, apply the provision that provides the greatest protection.

10. A grievances management mechanism is in place

10.1. It is necessary to implement a grievances management mechanism, which will allow for the filing of grievances, which arise from specific business activities and/or functions of any nature, by individuals, employees, communities, other interested parties (customers, suppliers, subcontractors, etc.).
10.2. The grievances filed may be anonymously or by name, observing complete confidentiality.
10.3. Redressal of all nature of grievances is of utmost importance and should be handled adequately and thoughtfully.

For Papayianni Bros S.A
The Management

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