Aim of “INTROFEX S.A.” is to establish a complaints mechanism which enables people, employees, communities, and/or civil society, buyers, suppliers, including the complainants, to freely express their complaints and to submit any report that they consider to be well-founded and true.
1. This Policy sets the principles and the operational framework under which the Company shall receive, process and investigate named or anonymous reports of complaints, serious irregularities, omissions or other offenses which came to the notice of the personnel, the customers, the suppliers, or any third party .
2. The Company shall guarantee the highest ethical standards and professional behavior and zero tolerance towards any illegalities and infringing actions which may affect its status and reputation.
3. The reporting process concerns all personnel, all customers, anyone providing services to the company as well as any third party. More specifically, the opportunity to submit named or anonymous reports concerns the following people: the Members of the Board of Directors, any person who is engaged in any administrative duties, the employees, the suppliers, the customers, any third party having proof and/or information about complaints, illegalities and infringing actions regarding the company.
4. This Policy aims to ensure the integrity, the status and the reputation of the Company, to contribute to the early risk warnings and to the taking of the appropriate remedial measures as the case may be, so as to strengthen the confidence and security of personnel, suppliers, partners and third parties, who are asked to report to the Company any complaint, illegality or infringing action which come to their notice. The reporting process aims to strengthen transparency, which encourage the report of occurrences that give rise to suspicion of serious infringements to the Company’s procedures and policies, as well as to uncover incidents of fraud, corruption, coercion or other infringements.
5. The Company shall protect the anonymity and confidentiality of personal data of people submitting reports.
6. The reports shall be made under the honest and reasonable belief that the reported incident has occurred, in case it is linked to any act or omission. The Company’s personnel, customers or suppliers, as well as any third party shall be asked to report complaints, offenses, suspected cases of illegal behavior, incidents of mismanagement or serious irregularities - omissions as regards the Company's policies and procedures. Indicatively: Incidents concerning complaints from customers, actions having characteristics of gross negligence, suspicion of fraud or corruption, actions or omissions affecting Company's reputation, conflicts of interests, irregularities and infringements of policies and procedures which may cause financial loss to the company, actions and omissions which endanger the safety of the employees, actions concerning the offering or receiving of a bribe or actions or omissions which may cause damage to the environment resulting in Company’s financial loss.
7. Reports can be submitted anonymously or named via mailing to: 15 Themidos Street, Agios I. Rentis or via e-mail at firstname.lastname@example.org or via phone at: + 30 210 4836 352. The Company shall maintain the confidentiality and protect the identity of the person submitting the report, where they decide not to be anonymous. It shall be noted that the disclosure of the reporter's identity may be required during judicial or other legal procedure, within the investigation of the report. Only a limited number of people defined by the Company for the reports’ investigation shall take notice of them and they shall be bound to respect the privacy and confidentiality rules. Therefore, the persons mentioned in the report are protected until the investigation of the matters reported is completed.
8. The Company shall protect the persons reporting when they are its employees, from any retaliation which may affect their development or the continuation of their employment. Any person submitting a report shall be protected in terms of the corporate environment from threats or discriminatory treatment resulting from the submission of the report.
9. Reports for the sake of completeness may include indicatively but not restrictively the reasons for this complaint, the suspicion/concern, referring to
names, dates, details and information, as well as the reasons leading to the submission of this report.
10. The reports shall be investigated by the Evaluation Committee for reports established by the Company, which has an annual term of office and in which people of both sexes are selected to participate. Employees of the company must also participate in the Committee. The Evaluation Committee for reports must have expertise and impartiality during the investigation of the reports and be accessible to anyone wishing to offer data or information concerning the reports under investigation.
In the event that a member of the Committee has a conflict of interest, they shall be replaced ad hoc by another person designated by the Company’s Management. The Evaluation Committee' decisions shall be taken by majority vote. In case the Evaluation Committee for reports assesses the report as significant and therefore serious irregularities, omissions or offenses result from it, in addition to the document of findings of the relevant investigation notified to the person submitting the report no later than one month after its submission, it shall recommend to the Company’s Management any further necessary measure.
The Committee shall be composed of the Food Quality and Safety Manager, the Human Resources Manager and the Food Quality and Safety Management Department Employee.
11. Any reports or complaints about human and labor rights shall be given the urgent attention and in case the relevant report is considered to be well- founded, all necessary restoration measures shall be taken in accordance with the relevant Restoration Protocol, drawn up in co-operation with the Equality Policy Team and notified to the individuals involved within a reasonable time frame.
12. All employees of the Company shall receive the appropriate information regarding the operation of the Evaluation Committee for reports though this procedure and for those who cannot read, the information shall be given orally. For anyone interested who is not member of the company, this policy is posted on the company’s website.
This policy is adopted by the Board of Directors of the Company and is notified to all personnel for their information.
28 April 2022