MYTILINEOS, 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 Energy & Metals S.A. (the company) encourages the use of the available corporate (internal) reporting channels to ensure timely review and appropriate management attention.
Whistleblowing reports through the corporate METLEN Energy & Metals S.A. whistleblowing channels, can be submitted by employees linked to the Company by any type of current, former, candidate employment relationship, as well as any person working under the supervision and direction of contractors, subcontractors and suppliers of METLEN Energy & Metals S.A.
Our company takes all appropriate technical and organizational measures to ensure Personal Data Protection, confidentiality, and protection of the whistleblowers from any form of retaliation under the conditions of the Greek laws 4990/2022 and 4808/2021.
The Whistleblowing procedure should not be abused with the submission of ill-considered accusations or personal complaints. To prevent the submission of malicious or unsubstantiated reports, sanctions may be imposed on employees who have acted in bad faith. In such cases, the laws on defamation in force in the countries where the Company operates shall apply.
What should be reported
Topics that fall under the scope of the Greek Law L.4990/2022 (public procurement, financial services, products and markets, including the prevention of fraud, corruption and other illegal activities and the prevention of money laundering and terrorist financing, product safety and compliance, transport safety, environmental protection, public health, consumer protection, protection of privacy and personal data, as well as the security of network and information systems, radiation protection and nuclear safety, food safety, animal health and welfare), issues affecting the financial interests of the Union, issues related to the free movement of goods, persons, services and capital, as well as issues concerning the Greek Law L.4808/2021 on the matters of Prevention and Combating Violence & Harassment at Work.
Available Channels to submit a Whistleblowing report.
The Whistleblower shall receive an acknowledgement of receipt of the report within seven days of its submission, as well as information on the actions taken by the competent bodies of the Company within three months of the submission of the report.
The submission of Whistleblowing reports through the communication channels #1 & #2 takes place in an environment of complete confidentiality, and, at the choice of the Whistleblowers can be done anonymously. After submission through channel #1, the Whistleblower receives a unique identifier from the Whistleblowing platform so that he/she can later log into the virtual mailbox of the Whistleblowing platform and answer questions raised by the evaluation team or be informed about the progress of his/her report. Through channel #2, communication with the whistleblower is performed through email without disclosing the whistleblower’s email address to the Company.
Individuals may also submit reports to external whistleblowing channels operated by the National Transparency Authority (NTA) as per law 4990/2022. https://aead.gr/submit-complaint
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.
