Compliance with Laws

The Company must comply with the laws of the republic of Cyprus and any other country in which we do business. We are each responsible for knowing and following all applicable laws, rules, and regulations.

Our Company must act in a manner that upholds the spirit and intent of the law. Where the Standard or Company guidelines differ from local laws or regulations, we must always follow the higher standard.

Violations of laws, rules, and regulations have serious consequences, both for the Company and for the individuals involved. Therefore, when questions arise on these or other legal matters, you should always seek guidance from Legal Department.

Laws of Equal Employment Opportunity

All employees and applicants shall be treated equally according to their individual qualifications, abilities, experiences and other employment standards. There will be no discrimination due to race, religion, color, national origin, sex, age, disability or veteran/military status. The prohibition of discrimination based on sex includes sexual harassment.


Employees should avoid contacts with competitors and their employees except in those limited situations where contacts are clearly necessary and for a lawful purpose.

Antitrust laws, sometimes also called competition laws, govern the way that companies behave in the marketplace. Antitrust laws encourage competition by prohibiting unreasonable restraints on trade. The laws deal in general terms with the ways companies deal with their competitors, customers, and suppliers. Violating antitrust laws is a serious matter and could place both the Company and the individual at risk of substantial civil and criminal penalties.

When questions or concerns arise regarding antitrust matters, such as, for example, price manipulation, market division, tying arrangements, certain exclusive or collusive dealing agreements, or other activities that may unlawfully restrict competition, please contact the Legal department.

Bribery, Anti-Corruption, and Business Dealings with Governments

The Republic of Cyprus, EU and many other countries have bribery and other anti-corruption laws that are intended to prevent companies and individuals from gaining an unfair advantage and from undermining the rule of law. The Company and our directors, officers, and employees must never offer or accept bribes, kickbacks, payoffs, or other considerations that could potentially be interpreted as unfair and illegal and must not participate in or facilitate corrupt activities of any kind.

This prohibition on offering or paying bribes of any kind also applies to third parties acting on the Company’s behalf, such as third party contractors, consultants, or agents. The Company must never engage a third party who we believe may attempt to offer a bribe of any kind to conduct Company business.

Environmental Management and Compliance

It is the policy of the Company, as an environmental leader, to protect the environment for the health, safety and quality of life of our communities, our employees, our customers and the public.

Compliance is the baseline of performance for the Company and all of its employees. A number of environmental laws, standards, requirements, and policies apply to our business operations, practices, and products.

The Company expects our suppliers and others to comply also with all applicable environmental and health and safety laws and standards in their operations.

Any violation of these policies could result in corrective action, up to and including immediate termination, monetary liability, and, in some cases, criminal liability.

Export and Import Compliance

It is the responsibility of each employee to ensure that the relevant export laws, regulations and procedures are being followed when that employee is exporting goods. This responsibility includes verifying that the correct license is used on any export declaration or other document required for export.

Each employee is expected to understand and comply with the laws and regulations that apply to importation of merchandise.

In no event should any employee or agent attempt to transport from one country to another, or otherwise carry on their person with the intent to transport from one country to another, any merchandise which have not been appropriately declared with customs officials and duty paid.

Violations, even inadvertent ones, could result in significant fines and penalties, denied export licenses, loss of export privileges, or Customs scrutiny and delays.

Any Company director or employee who is aware of material, non-public information regarding the


Many countries have implemented, or are planning to implement, privacy laws that set requirements for the appropriate handling of personal data, including any information that can be used to identify, contact, or locate an individual.

The Company is committed to protecting the reasonable privacy expectations of everyone we do business with, including our customers and employees. Therefore, each employee has a responsibility to comply with the Company’s privacy and information security requirements when personal data is collected, stored, processed, transmitted, and shared. Additionally, each employee must comply with the requirements of any confidentiality and non-disclosure agreements with our customers, suppliers, vendors, or other third parties.