METLEN, as a responsible business citizen, fully integrates in its activity the regulatory framework defined by both Greek and European legislation, as well as the international forums in which it participates.
As part of the continued commitment of METLEN to effective corporate governance, the Code of Business Conduct sets out the general principles which define the responsible business conduct and the ethical rules that all the employees throughout its operations as well as its business partners such as contractors and suppliers are expected to adhere to. The Code is of major significance for the Group, as adherence to it contributes substantially towards the attainment of the Group’s core strategic goal of Continuous and Responsible growth. The Code ensures that all Group activities taking place adhere to the principle of integrity, thus safeguarding the Group’s reputation, which is its most valuable intangible asset and, as any other asset, should not only be protected but should also be further developed, by ensuring that the conditions that will allow this are in place.
As part of the continued commitment of METLEN to effective corporate governance, the Code of Business Conduct sets out the general principles which define the responsible business conduct and the ethical rules that all the employees throughout its operations as well as its business partners such as contractors and suppliers are expected to adhere to. The Code is of major significance for the company, as adherence to it contributes substantially towards the attainment of the Group’s core strategic goal of Continuous and Responsible growth. The Code ensures that all METLEN' activities taking place adhere to the principle of integrity, thus safeguarding the company's reputation, which is its most valuable intangible asset and, as any other asset, should not only be protected but should also be further developed, by ensuring that the conditions that will allow this are in place.
A crucial part of the Compliance system is the compliance related training. Trainings support the development of an ethical culture through out the entire organization. Trainings not only create awareness to the employees on the applicable legislation and the internal policies, but also offer solutions on daily business matters by detailing applicable case studies. The training objective is to help employees identify troublesome situations, to provide them with ways to get through them and in case of ambiguity to provide them with the proper escalation channel that will support them.
There are various compliance training topics the most important of which is the training on the METLEN code of conduct that includes all topics contained in the code with a deep analysis on each of them. There are two training formats, the in person training and the web based training. Although in person trainings encourage lively discussion with the instructor and may go beyond the training material, web based trainings allow the wide distribution of the material through out each country employees are located into and also provide the necessary flexibility to the employee to complete it at his/her own time plan. Training participation/ completion is tracked with the goal all employees invited to achieve completion.
The protection of natural persons in relation to the processing of personal data is a fundamental right. Article 8 para. 1 of the Charter of Fundamental Rights of the European Union (the “Charter”) and article 16 para. 1 of the Treaty on the Functioning of the European Union (TFEU) provide that everyone has the right to the protection of personal data concerning him/her.
Furthermore, under General Data Protection Regulation (GDPR) No. 2016/679 of the European Parliament and the Council which came into effect on 25.05.2018, a stricter framework has been introduced for the protection of individuals with regard to the processing of their personal data and for the free movement of such data (the “General Regulation”).
The protection of natural persons with regard to the processing of personal data is of the utmost importance for METLEN (the “Company”); consequently, the Company collects and processes personal data strictly in conformance with the General Regulation and the applicable legislation in general and to the extent necessary in connection with some aspect of labor relationships and the business of the Company. The Company limits the access to such data to authorized persons only, and takes enhanced data security measures to secure data against -among others- loss, mishandling, unauthorized access, alteration or disclosure.
Cookies are small text files that a website saves on your computer or mobile device when you visit a site.It enables the website to remember your actions and preferences over a time period to provide a more user-friendly service. In addition, some cookies serve METLEN commercial advertising or/and promotion. In this section, we generally use the term "cookies" as an “umbrella term” to describe techniques such as cookies, Flash cookies and web beacons.
On our premises we use the closed circuit television system for the protection of persons and goods. The personal data processing is necessary for the protection of our legal rights as data controler (article 6 par.1 of GDPR)
According to the Market abuse Regulation and the Hellenic Capital Market Commission, Persons discharging managerial responsibilities in METLEN, as well as persons closely associated with them, shall notify METLEN and the Hellenic Capital Market Commission on their transactions regarding METLEN securities within a three day period.
Compliance retains a catalogue of all persons discharging managerial responsibilities, that includes persons/ legal entities closely associated with them, and informs them regularly about their obligations and the blackout periods before the announcement of the financial results.
METLEN expects that all its partners hold similar standards of integrity when acting on its behalf. For this reason METLEN has established a detailed process of business partner compliance due diligence for certain types of cooperations.
The business partner is actively cooperating with METLEN and provides all necessary documentation/ information, as required, before any contractual agreement is made. After the collection process has been completed a Compliance Officer is checking the due diligence for completion and remaining red flags and sends the recommendation to the responsible Manager that shall approve or decline the cooperation. Any cooperation is then monitored for red flags during its duration.
METLEN (Metlen Energy & Metals plc and all its subsidiary companies) encourages the use of corporate internal reporting channels to ensure timely review and appropriate management attention.
Who Can Submit a Speak Up Report
Speak Up reports can be submitted by anyone in a business relationship with METLEN who wishes to raise a concern about suspected misconduct related to the business activities of METLEN. This may include, indicatively, employees (current, former, prospect), and contractors of METLEN.
What can be reported
The Speak Up channels can be used to raise concerns about suspected misconduct related to METLEN's operations. This includes (but is not limited to) any breach of applicable laws and/or violations of METLEN's Code of Business Conduct and/or violations of METLEN's policies or procedures. The channel is not intended to host customer complaints or employee grievances.
METLEN takes all appropriate technical and organizational measures to ensure the protection of personal data and the confidentiality of information.
Non retaliation policy of METLEN
METLEN’s is committed to protecting the reporting persons from any form of retaliation provided that the reports are made in good faith even if they come out to be unsubstantiated. Reporting persons should bear in mind that if they deliberately file false reports in bad faith, disciplinary actions may be imposed on them and also they may be exposed to defamation charges depending on the applicable local legislation.
METLEN Speak Up channels
Speak Up reports can be submitted through the following options:
Both channels support anonymous reporting to METLEN.
After submission through the above channels, reporting persons receive an acknowledgement receipt and a unique identifier from the Speak Up platform. With these credentials they can later log into the virtual mailbox of the Speak Up platform, reply to any clarification requests raised by the report evaluation team and/or get informed about the progress of their report till it’s completion.
External and public reporting
METLEN encourages all employees and contractors to raise concerns internally through one of the available channels. Speak Up reports filed internally, give METLEN the chance to look into the matter and take action if needed. In this way we can truly improve together.
However, in many countries where METLEN operates, national legislation provides for individuals to raise concerns with public authorities in respect of specific suspected violations of legal or regulatory requirements or even file a public disclosure under strict conditions. The protection measures against retaliation outlined above apply equally in respect of external or public reporting which is in scope of local legislation in the jurisdiction in which the external report is filed. Please refer to country specific legislation before you consider reporting externally or publicly.
METLEN Energy & Metals S.A. recognizes that fraud, corruption and bribery are serious and difficult issues that concern modern entrepreneurship internationally, threatening good administration, undermining economic and social development and distorting free competition.
The Company, which operates, itself and / or through its subsidiaries, internationally, and inter alia, in areas and objects of high risk in matters of fraud, corruption and bribery, recognizing the risk of being exposed to such phenomena, in a national and international environment, has been certified in accordance with the requirements of ISO 37001: 2016 (anti bribery management system) and establishes the relevant anti-fraud policy, corruption and bribery.
