CODE OF CONDUCT

Introduction

What is the Code of Conduct of Rodoula?

The Code of Conduct serves as a record of the general principles which define the responsible business conduct and the ethical rules that all the employees and business partners of Rodoula are expected to follow, as well as a record of the commitments of Rodoula’s Management towards its people.

The Code ensures that all Rodoula’s 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.

To whom is the Code of Conduct addressed?

The Code is addressed and applies to the persons already employed in Rodoula, irrespective of their position in the management hierarchy (e.g. CEO, BOD members, administration executives and employees).

Moreover, the Code is also addressed and applies to business partners and consultants to the extent they are representing or acting on behalf of Rodoula on the basis of outsourcing agreements or of any other business agreement.

The Group’s employees must be aware of the following:

The Code is of major significance for Rodoula, as adherence to it contributes substantially towards the attainment of the Rodoula’s core strategic goal of continuous and responsible growth.

The Code covers the rules of acceptable conduct of employees towards third parties, which may be persons or legal entities operating under private or public law, operating in Greece or abroad. At the same time, by extending beyond Rodoula’s mere compliance with the laws in force in all its activity sectors, the Code demonstrates Rodoula’s commitment to always operate in accordance with the principle of integrity.

The Code’s development takes into account the business activities of Rodoula worldwide, the applicable laws governing these activities, the high-quality services and products that Rodoula provides and the standards of professional conduct it has adopted as a prerequisite for pursuing the aforementioned business activities.

Why is the Code of Conduct necessary?

The decisions we are called upon to make and carry out as individuals in the context of our work affect our colleagues and Rodoula. The Code is necessary in order to ensure that all activities are carried out in a manner characterized by transparency, honesty and integrity. With our decisions and actions, we can all help fulfil our commitment to ethical business practices and values, improve the environment in which we work, win the trust of our clients and build Rodoula’s reputation.

Management’s commitment towards the employees

Rodoula is its people with whom the company shares the same passion and visions for the creation of new trends when it comes to products. The team is growing and the people who join the team have to share the same values. An element of Rodoula’s success is that it grows and evolves in parallel with its people. It is notable that most of its personnel personnel comes from the nearby area and they have been working for the company since its start, strengthening the local society with employment positions.

 

Rodoula’s Management functions with a sense of responsibility and consistency towards employees. Investing in human capital is an integral part of Rodoula’s corporate culture, as the attainment of business goals, the achievement of positive results and Rodoula’s continuous growth relies on its people.

In line with the above, Rodoula’s Management:

  • Is committed to maintaining and further enhancing a safe work environment that promotes mutual trust, collaboration and recognition.
  • Promotes equal opportunities for employment in all Rodoula’s activity sectors, adopting recruitment practices that are fully consistent with the conditions and criteria provided for by the legislation in force. These criteria are based on the capabilities, educational qualifications and legal age limits with regard to employment of every individual, regardless of gender, nationality, color, sexual orientation, origin or physical ability.
  • Provides work areas that encourage diversity and teamwork and achieves excellence by attracting and retaining knowledge and value – driven individuals.
  • Complies with the applicable labor, accounting and employment laws as well as with applicable laws on intellectual property.
  • Invests a considerable part of its income every year on educational programs which form new basis and new perspectives for all the employees. The continuous education and training refers to all levels and all units within the company.
  • Operates in accordance with the fundamental principles of human rights and supports the efforts to bring balance between working and personal life.
  • Protects the personal data of employees, allowing their use only by authorized persons and only in cases where this is required by the law for purposes related to the functioning of the labor relations and to Rodoula’s business activity.
  • Ensures a safe, healthy and well-structured working environment with facilities which are friendly to the employees, providing all the means of protection.

For these purposes, Rodoula has incorporated into its practices methods and systems for the development of human resources, thus ensuring the conditions for the continuous development of its employees, the encouragement of creative expression and thinking and the fulfilment of their personal and professional aspirations.

The role of Executives

The role of Rodoula’s team of Executives (BOD members and Managers of Departments) is a key to creating and maintaining a work environment that promotes integrity, collective work and trust. Rodoula’s Human Resources Department, in collaboration with other Department Managers, where considered necessary, ensures adherence to the rules of proper corporate and personal conduct across Rodoula.

In particular, the role of Executives focuses on the following priorities:

  • Ensuring that the Code of Conduct is available to all employees in their departments, , and that it is understood by all of them.
  • Promoting, by example, the standards and behaviors described in the Code.
  • Ensuring that the employees in their departments have received, where required, appropriate training that will allow them to comply with the Code of Conduct.
  • Creating an environment that is open to the expression of concerns and provides assistance and support to personnel, in order to ensure that issues concerning compliance with the Code are identified and addressed effectively.

Principles of professional conduct

Business ethics

The ethos of a business is primarily composed of concepts such as integrity, transparency, meritocracy and accountability, and of the manner in which these concepts are applied.

Employees’ awareness:

  • Business Ethics do not merely stand for compliance with legal, regulatory, professional and business standards; instead, they represent – first and foremost – the deployment of the business activity in a spirit of fairness, integrity, honesty and respect.
  • Business Ethics are a key prerequisite for a modern, high-performance company such as Rodoula. The employees’ contribution to building a climate in which they appreciate, understand and share specific common values, leads to a high added value to Rodoula and helps it achieve long-term, sustainable business growth.

Legal compliance

For Rodoula, making every possible effort to ensure that its business activities are carried out in complete harmony and compliance with, and fully adhere to, the applicable laws and the operating principles that govern the activities concerned, in every geographical region or country where it operates, is a fundamental and non-negotiable principle.

Employees’ awareness:

  • Every violation of the law exposes Rodoula to risks, whose extent and impact, in both economic and social terms, may have incalculable consequences.
  • Rodoula considers it self-evident that its employees, irrespective of their position in the management hierarchy, participate in the efforts to meet the requirements of the law and to observe the supporting procedures that Rodoula and its subsidiaries introduce to this end.

Conflict of interests

Conflict of interests involves circumstances where individuals must make a choice between the demands of their position and their private interests.
In this sense, all Rodoula employees – i.e. executives, non-executive personnel, administrative employees, technical & labor personnel – are required to refrain, in the performance of their duties, from activities which seek to obtain private financial interests or other personal benefits and are inconsistent with their professional activity in Rodoula.

Employees’ awareness:

  • avoid making unfair use of their position for the benefit of their relatives or close associates.
  • apply caution with regard to gifts or other benefits offered by persons wishing to establish a business in relation with Rodoula and do not accept items or other gifts of significant value, offered with the intention to influence their judgement.
  • inform their Manager or the competent Human Resources Department, if they consider a second employment or participating in a competitor’s or corporate partner’s share capital.

Protection of assets

The General Managers and Senior Executives are responsible for developing, implementing and managing appropriate policies to safeguard Rodoula’s assets.

Employees’ awareness:

  • protect Rodoula’s property, tangible and intangible assets and resources of all types, pay due attention in their use, which must be exclusively for serving work purposes, and take all due care to ensure that they are not wasted, damaged, destroyed or lost due to theft.
  • Drivers of corporate vehicles should adhere to the highway code and in case of its violation, they are exclusively responsible before the applicable legislation.
  • It is strictly prohibited to smuggle Rodoula’s assets. In the event of smuggling goods, Rodoula has the right to terminate the employment relationship with the employee who has performed the offence, without paying the stipulated in the law compensation and file a complaint against the employee.

 Integrity of financial data

Rodoula applies strict standards to ensure the accuracy, correctness and completeness of the financial data kept and of its financial reports, seeking to ensure transparency in its financial reporting. The Financial Statements are prepared and released in accordance with the applicable laws.

Employees’ awareness:

  • Rodoula’s accounting records and supporting documents have been designed so as to describe and reflect the true nature of its transactions, as well as to comply with the accounting standards in force.
  • Correct and accurate record-keeping is essential for Rodoula’s smooth operation. Records are used to store and keep all information created and used in the pursuance of Rodoula’s activity. All Rodoula’s records and books must be accompanied by the necessary documents establishing the validity, accuracy, completeness and efficiency of the transactions made. Employees who, due to the nature of their work are keeping records, must ensure the accuracy and completeness of such records.
  • Cooperation with the external and internal auditors must be full and effective. Rodoula’s employees and executives must, in the framework of their duties, forward to the auditors accurate and true information regarding Rodoula’s financial, so as to ensure that the picture given, in accordance with the above, is an accurate and complete one.

 Protection of confidential information & commitment to privacy

Information of a confidential or secret nature is information which has not been disclosed or is not available to the general public. Such information includes financial or technical information, contracts/agreements, personal data of employees and clients/associates, plans for acquisitions/mergers and significant management changes or information about Rodoula’s development and strategy in general. It also includes data regarding Rodoula’s intellectual property rights or patents, business research, plans for new products, strategic goals, any unpublished financial or non-financial data, pricing information, lists of clients and suppliers, as well as information on claims, business options.

Furthermore, at Rodoula we recognize the importance of, and are fully committed to protecting the privacy of personal data related to all individuals with whom we interact by complying with all applicable data protection laws and regulations. Data security is of the outmost importance for Rodoula. For this purpose, we protect all the personal data of our employees, customers, partners, consultants by the implementation of all the appropriate technical and organizational means to prevent any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access.

Employees’ awareness:

  • in the exercise of their duties and in all their transactions or relations of any nature with third parties, they must not disclose or make available in any way information owned by Rodoula which is confidential or secret.
  • safeguard the confidential and secret information owned by Rodoula, irrespective of how and why they have become aware of it, and must not disclose it to persons outside Rodoula, including their family members and friends, throughout their employment relation with Rodoula as well as after its expiry or termination. Exceptions to the foregoing are cases where the disclosure of such information to third parties is required by the law or in order to better serve operational needs. The restrictions in the shared use of confidential information apply until such information becomes available to the public in some other way.
  • in case that during their employment related duties have access to personal data of other employees, BoD members, suppliers, partners or customers, they are obliged to comply with the applicable data protection laws and regulations as well as with internal policies and procedures regarding the processing of such personal data (e.g. report any violation of privacy, disclose personal data only to authorized parties, store and/or delete personal data in safe manner, etc.).

Fair competition

Rodoula undertakes that its activities conform to fair competition and take place in strict compliance with the provisions of all applicable laws in the various countries where it operates.

Irrespective of their position in the management hierarchy, Rodoula’s employees involved in commercial activities must be aware that:

  • Any comparisons made between the Rodoula’s products and those of its competitors should be accurate and documented.
  • They must not use any unfair means against Rodoula’s competitors, through manipulation, concealment, abuse of insider information, misrepresentation of key data or the negotiation and conduct of any unfair transactions.
  • They must carry out fair transactions with clients, suppliers and competitors and must conduct themselves in a way that is based on merit and always in accordance with the rules and the principles of fair competition.
  • Violations of the competition law expose Rodoula to significant financial penalties under applicable law and damage its reputation, with potentially serious overall consequences for Rodoula.

Relations with our suppliers

Rodoula offers equal opportunities to all existing or candidate suppliers and demands its suppliers to apply the same integrity standards as we do.

Rodoula’s decisions regarding its business relations with suppliers are based on objective criteria such as the following: quality of the products and services offered, provision of full and prompt customer service, pricing policy, solvency, punctuality in the delivery of products and services, compliance with the key principles of sustainable development and in particular with specific environmental and social criteria, availability of appropriate technological infrastructure matching the specific needs of Rodoula, supplier experience and integrity.

Employees’ awareness:

  • the objective is to secure reliable and uninterrupted supply sources through the evaluation process, which helps protect the reputation of Rodoula.
  • Rodoula will terminate any business relation with a supplier or contractor who is found to apply unlawful practices and in contradiction with this Code.

Relations with customers

Rodoula’s relations with its customers is governed by transparency, trust, respect, honesty and integrity, securing in this way their trust and their engagement in the development and maintenance of long-term business relations. We create products which meet our consumers’ needs for a balanced diet. Our aim is to deliver added value continuously. This can be achieved when we take care of and fulfill our customers’ needs, desires and expectations to the greatest possible extent. Our customers expect us to deliver new innovative and high quality products and customized service.

Employees’ awareness:

  • The provision of high-quality products and services, in full compliance with health and safety legislation in force , is a core commitment of Rodoula’s Executives and, by extension, of all its employees.
  • Decisions that might undermine the trust of our customers and put at risk Rodoula’s quality of products and its reputation are not allowed.
  • Treat the customers/prospective customers in an ethical and fair manner and in compliance with applicable laws (for example: presentation of the characteristics and/or packaging of the products in an honest manner; avoidance of any illegal or misleading methods; communication of Rodoula’s sales’ programs if applicable; provision with exactly what the customer really needs; make no gender/ethnicity/region based discrimination).
  • Our respect to our customers is also reflected by Rodoula’s practices with regard to the protection of privacy. In particular, the collection of personal data is limited to the collection of information which is essential for the provision of products and services or to information which is provided voluntarily and with the customer’s freely given consent. The disclosure, supply or use of personal data for purposes other than those specified by Rodoula is not allowed, with the exception of customer information and disclosure with his/her free consent or when required by applicable law.

Quality Assurance

Products for everyday consumption with such commercial development could not be randomly produced. We use the purest ingredients and we create authentic recipes’ that distinguish in the markets.

The main aim is to have consistent partnerships with renowned Houses that follow from their end international production standards. All of our products go through the shock freeze process which retains the initial characteristics of the product unaltered. Moreover, Rodoula follows International food and safety standards and has acquired all the necessary quality assurance certificates, including ISO, IFS and BRC certifications. Due to its international activities is certified as well as with Halal and Kosher certificates.

The traceability system of the company makes it feasible for the company to have full control of its supply chain and assure the delivery of high-end service to the end recipient.

 

 

Contacts with Government Authorities & Relations with the Media

Cooperation and contacts with Government Authorities are governed by specific rules.

Employees’ awareness:

  • All employees or business partners who, as of the nature of their work, communicate with regulatory authorities, industry bodies and Government officials, should adhere strictly to the guidance provided by the Legal Counsel and by their Department Manager.
  • Bribery of public or Government officials and the extension to them of any type of personal facilitation are strictly prohibited.
    As the reputation of Rodoula also depends on the establishment and selection of appropriate communication channels, all media communication activities take place after appropriate guidelines provided by the competent Department.
    Employees’ awareness:
  • communication with the Media is the responsibility of specific individuals who Rodoula has expressly authorized for this purpose.
  • In cases where they receive questions on corporate matters to which they are not expressly authorized to respond, they should forward these to the competent Department.

Strengthening Transparency

Compliance with laws against bribery and corruption is mandatory. Business decisions must not be affected by private interests or personal benefit or corruption (“corruption” generally refers to acquiring or trying to acquire personal benefit or business advantage through inappropriate or illegal means). Corruption may refer to payments or the exchange of any valuable object and includes indicatively bribery; blackmailing and illegal procurements.

Employees’ awareness:

  • Rodoula’s Executives undertake to uphold transparency in the entire range of Rodoula’s activities and in its financial reports. It also prohibits the offering or taking of any and all unlawful commissions, bribes to/from any public or Government official or the conduct of similar transactions of any type with such persons.
  • Rodoula’s employees or business partners are not allowed to offer or receive, either themselves or the members of their families, gifts, discounts, fees, benefits or other considerations (of a financial or other nature) to/from company clients, suppliers public or other organizations or any third party, which are directly or indirectly related to their capacity as employees of Rodoula,with the exception of cases where these are acceptable in the framework of customary business practice. In all cases, any such benefits should only be made in the context of business relations and should conform to the appropriate due measure. Additionally, care should be taken to ensure the integrity of the business relation concerned and to avoid creating a situation giving rise to conflict of interests or conditions which could be construed as bribery.
  • It is Rodoula’s policy to make no donations whatsoever to political groupings or to persons related to them. In addition, all employees or business partners are prohibited from representing Rodoula from appearing to act on their behalf, in any political activity in which they participate in their private lives.
  • Each employee or business partner of Rodoula is personally responsible for ensuring the transparency of his/her actions. The commitment of offences involving corruption or bribery by an employee or business partner incurs all legal consequences and may lead to the prompt termination of the concerned person’s contractual relation with Rodoula.

Health & Safety at the workplace

The protection of health and safety in all of Rodoula’s activity sectors is of the utmost priority. Achievement of the “zero accidents” goal in the workplace, is the responsibility of all employees.

The Management ensures that Rodoula’s activities are carried out in compliance with the legal and regulatory provisions in force and with the corporate standards and best practices on health and safety. In addition, account is taken of all reasonable and practicable measures which ensure a safe and healthy work environment and help minimize risks.

Employees’ awareness:

  • They are personally responsible for ensuring their own safety and health in their area of work, to the maximum extent foreseen under their work duties and to the best of their knowledge, abilities and experience.
  • They must take care of the safety of their colleagues and of the visitors to the areas where they work.
  • They are invited to report their concerns and to identify areas in their work (such as non-safe work conditions and behaviors including violence in the workplace) in need of improvement regarding health and safety, thus making an ongoing contribution to the efforts to build a better and safer work environment.
  • They are prohibited to work under the influence of alcohol, drugs or other substances.

Protection of the Environment

Rodoula’s business strategy is inextricably linked to sustainable long-term development. In line with this view, Rodoula regularly applies practices aimed at ensuring the continuous improvement of its environmental performance. As with its business activity, Rodoula’s intention and goal is for its processes, services and products to have the minimum adverse impact on the environment. Consequently, the prudent protection of the natural environment is an integral part of Rodoula’s business activities.

Support the Society

From its establishment to this day, the history of Rodoula has been interwoven with the economic growth of Greece and especially of the Greek borough. This is a constantly evolving effort which takes various forms, all of which hinge on Rodoula’s undertaking to understand and respond to the concerns of local communities, by means of the open social dialogue processes it applies, as well as to build associations that yield multiple benefits, create added value and strengthen social cohesion.

Furthermore, Rodoula has intense social contribution and promotes volunteering within Rodoula’s society through the idea of social offer. In particular, Rodoula encourages its employees to participate in voluntary initiatives and actions carried out by Rodoula and/or its subsidiaries in which they work, through which they can actively help provide relief to specific vulnerable social groups (including children and young persons, elderly people, people with disabilities, refugees or returning refugees, indigenous populations and ethnic minorities).

Beyond its contribution to the economic development of the local communities where it operates, Rodoula is consciously and actively supporting their balanced and varied development, through actions that:

  • assist in the development of local infrastructures;
  • protect the environment; ➢ strengthen employment;
  • help mitigate the effects of poverty; and
  • promote culture and support education.

Adherence to the Code

The Managers, Department/Service Supervisors have an increased responsibility to ensure adherence to the Code. If any Executiveor is aware that an employee intends to commit an act prohibited under the Code and does not take any measures to prevent this, the Executive concerned shall be considered equally responsible.

Employees’ awareness:

  • Read and understand the Code, seek guidance when required and conform to its spirit. ➢ Refrain from any behavior which is contrary to the Code’s principles and might damage Rodoula’s reputation.
  • Inform, in the performance of their duties and in their transactions with third parties, such third parties of the Code and draw their attention to the requirement for compliance with its rules, if required.
  • Consult their Supervisor or Manager, if they are in any doubt as to whether any of their activities might be regarded as a violation of the Code.
  • Ignorance of the provisions of the Code by an employee is not excused and does not release the employee concerned from his/her obligation to comply with such provisions.

Reporting of violations of the Code of Conduct

Rodoula expects for its employees to report violations of this Code of Conduct, when they become aware of them or when these are brought to their attention. This will allow Rodoula to address and rectify the matter – ideally, before it becomes a violation of the law or a health and safety risk or jeopardizes Rodoula’s reputation. In cases involving violations of the Code, the competent departments shall investigate thoroughly the relevant reports, while at the same time observing the confidentiality of the relevant information, unless otherwise provided for by applicable law.

Employees’ awareness:

  • They are encouraged to report freely any activity of which they have become aware of and which deviates from the Code’s principles and may give cause for concern.
  • Such reporting is crucial for avoiding or mitigating a potential negative impact on the company where they work and, by extension, to the Group. It also helps build a culture of transparency, responsibility and integrity.
  • Reporting a violation with mention of the reporting person’s identity is more credible and at the same time allows direct communication with the person reporting the violation, for obtaining clarifications and additional information during the report checking procedure.
  • Rodoula’s Executives warrant that no action shall be taken against any employee who reports in good faith any actual or alleged violation of the Code.
  • The reporting procedure should not be abused by the submission of illconsidered accusations or personal complaints. .
  • Where employees wish to seek advice or raise a related issue, a number of options are available. Thus, they may contact any of the following: ▪ their Supervisor ▪ their Manager ▪ the Legal Counsel of Rodoula the
  • Cases involving violations of the Code may also be reported by phone, fax or post, as well as via electronic mail (with mention of the reporting person’s identity or made anonymously).

Violation of the Code

Violation of the Code of Conduct is assigned to Rodoula’s Administration Board and the Legal Services Manager.

Non-compliance with the rules of the Code is regarded as a misconduct and, in accordance with the applicable laws and regulations, may incur for the employee concerned, irrespective of his/her position in the management hierarchy and depending on the severity of the violation, disciplinary actions. including termination of employment, in accordance with the legislation in force as well as Rodoula’s internal corporate procedures.

 

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